Form 485BPOS Davis Fundamental ETF
No. 811-23181
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
FORM N-1A
REGISTRATION STATEMENT UNDER THE
SECURITIES ACT OF 1933
POST-EFFECTIVE AMENDMENT NO. 18
SECURITIES ACT OF 1933
POST-EFFECTIVE AMENDMENT NO. 18
and
REGISTRATION STATEMENT UNDER THE
INVESTMENT COMPANY ACT OF 1940
POST-EFFECTIVE AMENDMENT NO. 21
INVESTMENT COMPANY ACT OF 1940
POST-EFFECTIVE AMENDMENT NO. 21
DAVIS FUNDAMENTAL ETF TRUST
2949 East Elvira Road, Suite 101
Tucson, Arizona 85756
(520) 806-7600
Tucson, Arizona 85756
(520) 806-7600
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Agents For Service:
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Lisa Cohen
Davis Selected Advisers, L.P.
2949 East Elvira Road, Suite 101
Tucson, AZ 85756
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Richard Cutshall
Greenberg Traurig LLP
1144 15th Street
Suite 3300
Denver, CO 80202
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It is proposed that this filing will become effective:
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Immediately upon filing pursuant to paragraph (b) of Rule 485
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On March 1, 2026, pursuant to paragraph (b) of Rule 485
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60 days after filing pursuant to paragraph (a) of Rule 485
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On [ ] pursuant to paragraph (a) of Rule 485
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75 days after filing pursuant to paragraph (a)(2) of Rule 485
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On [ ] pursuant to paragraph (a)(2) of Rule 485
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This post-effective amendment designates a new effective date for a previously filed
post-effective amendment
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1
Title of Securities being Registered Common Stock of:
Davis Select U.S. Equity ETF
Davis Select International ETF
Davis Select Worldwide ETF
Davis Select Financial ETF
Davis Select International ETF
Davis Select Worldwide ETF
Davis Select Financial ETF
EXPLANATORY NOTE
This Post-Effective Amendment contains:
Davis Fundamental ETF Trust Prospectus
Davis Fundamental ETF Trust Statement of Additional Information
Part C
Signature Pages
Exhibits
Davis Fundamental ETF Trust Statement of Additional Information
Part C
Signature Pages
Exhibits
2
Davis Select U.S. Equity ETF | DUSA
Davis Select International ETF | DINT
Davis Select Worldwide ETF | DWLD
Davis Select Financial ETF | DFNL
Davis Select International ETF | DINT
Davis Select Worldwide ETF | DWLD
Davis Select Financial ETF | DFNL
March 1, 2026
Prospectus
Portfolios of Davis Fundamental ETF Trust are Actively Managed Exchange Traded Funds
Principal U.S. Listing Exchange: Cboe Global Markets, Inc.
The Securities and Exchange Commission has not approved or disapproved these securities
or passed upon the adequacy of this prospectus. Any representation to the contrary is a criminal offense.
Contents
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This prospectus contains important information. Please read it carefully before investing and keep it for future reference.
No financial adviser, dealer, salesperson, or any other person has been authorized
to give any information or to make any representations, other than those contained in this prospectus, in connection with
the offer contained in this prospectus and, if given or made, such other information or representations must not be relied on as
having been authorized by the Funds, the Funds' investment adviser or the Funds' distributor.
This prospectus does not constitute an offer by the Funds or by the Funds' distributor
to sell or a solicitation of an offer to buy any of the securities offered hereby in any jurisdiction to any person to whom it
is unlawful for the Funds to make such an offer.
Prospectus | Davis Fundamental ETF Trust | 2
The Fund seeks long-term capital growth and capital preservation.
This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.
| Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) | |
| Management Fees | |
| Other Expenses | |
| Total Annual Fund Operating Expenses | |
| Less Fee Waiver and/or Expense Reimbursement* | |
| Total Annual Fund Operating Expenses After Fee Waivers and/or Expense Reimbursements | |
The Adviser (as defined below) is contractually committed to waive fees and/or reimburse the Fund’s expenses to the extent necessary to cap total annual fund operating expenses at 0.65%. For purposes of this expense cap, operating expenses do not include foreign tax reclaim filing expenses. The Adviser is obligated to continue the expense cap through March 1, 2027 . The expense cap cannot be modified prior to this date without the consent of the Board of Trustees. After that date, there is no assurance that the Adviser will continue to cap expenses. The Adviser may not recoup any of the operating expenses it has reimbursed to the Fund.
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1 Year
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3 Years
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5 Years
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10 Years
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DUSA
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$ |
$ |
$ |
$ |
The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 8 % of the average value of its portfolio.
The Fund is an actively managed exchange-traded fund (“ETF”). Davis Selected Advisers, L.P. (“Davis Advisors” or the “Adviser”), the Fund’s investment adviser, uses the Davis Investment Discipline to invest the Fund’s portfolio principally in common stocks issued by large companies with market capitalizations of at least $10 billion. Under normal market conditions, the Fund will invest at least 80% of the Fund’s net assets plus any borrowings for investment purposes in equity securities issued by U. S. companies. The Fund is non-diversified and, therefore, is allowed to focus its investments in fewer companies than a fund that is required to diversify its portfolio. The Fund’s portfolio generally contains between 15 and 35 companies, although the precise number of its investments will vary over time. The Fund may invest a portion of its assets in financial services companies. The Fund may also invest in mid- and small-capitalization companies, which the Fund considers to be those companies with less than $10 billion in market capitalization. The Fund may invest up to 20% of net assets in non-U.S. companies. These non-U.S. company investments may include European Depositary Receipts (“EDRs”), American Depositary Receipts (“ADRs”), and Global Depositary Receipts (“GDRs” and together with EDRs and ADRs, “Depositary Receipts”). Depositary Receipts are receipts that represent ownership of shares of a non-U.S. issuer held in trust by a bank or similar financial institution.
Davis Investment Discipline. Davis Advisors manages equity funds using the Davis Investment Discipline. Davis
Advisors conducts extensive research to try to identify businesses that possess characteristics
that Davis Advisors believes foster the creation of long-term value, such as proven management, a durable franchise and business
model, and sustainable competitive advantages. Davis Advisors aims to invest in such businesses when they are trading
at discounts to their intrinsic worth. Davis Advisors emphasizes individual stock selection and believes that the ability to evaluate
management is critical. Davis Advisors routinely visits managers at their places of business in order to gain insight into
the relative value of different businesses. Such research, however rigorous, involves predictions and forecasts that are inherently
uncertain. After determining which companies Davis Advisors believes the Fund should own, Davis Advisors then turns its
analysis to determining the intrinsic value of those companies’ equity securities. Davis Advisors seeks companies whose equity securities can be purchased at a discount from Davis Advisors’ estimate of the company’s intrinsic value based upon fundamental analysis of cash flows, assets and liabilities, and other criteria that Davis Advisors deems to be material on a company-by-company basis. Davis Advisors’
Prospectus | Davis Fundamental ETF Trust | 3
goal is to invest in companies for the long term (ideally, five years or longer, although
this goal may not be met). Davis Advisors considers selling a company’s equity securities if the securities’ market price exceeds Davis Advisors’ estimates of intrinsic value, if the ratio of the risks and rewards of continuing to own the company’s equity securities is no longer attractive, to raise cash to purchase a more attractive investment opportunity, to satisfy net
redemptions, or for other purposes.
Principal Risks of Investing in the Fund
You may lose money by investing in the Fund. Investors in the Fund should have a long-term perspective and be able to tolerate potentially sharp declines in value.
The principal risks of investing in the Fund are:
Stock Market Risk. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices, including the possibility of sharp declines.
Common Stock Risk. Common stock represents an ownership position in a company. An adverse event may have a negative impact on a company and could result in a decline in the price of its common stock. Common stock is generally subordinate to an issuer’s other securities, including preferred, convertible, and debt securities.
Market Trading Risk. The Fund is subject to a number of market trading risks, which include the possibility of an inactive market for Fund shares, losses from trading in secondary markets, periods of high volatility and disruptions in the creation/redemption process. ONE OR MORE OF THESE FACTORS, AMONG OTHERS, COULD LEAD TO THE FUND’S SHARES TRADING AT A PREMIUM OR DISCOUNT TO NAV. The Fund’s market price may vary from the value of the Fund’s underlying portfolio holdings, particularly in times of market stress. This difference may be reflected as a spread between the bid and ask prices for the Fund shares during the day or a premium or discount in the closing market price of the Fund when compared to the NAV. An investor may pay significantly more or receive significantly less than the underlying value of the Fund shares bought or sold.
Exchange-Traded Fund Risk. The Fund is an actively managed exchange-traded fund and trades like common stock on an exchange. The Fund is subject to the risks of owning the underlying securities, as well as the risks of owning an exchange-traded fund generally. The management fees of an actively managed exchange-traded fund are generally higher and can increase the Fund’s expenses. The market for the Fund’s shares may become less liquid in response to the deteriorating liquidity in the market for the Fund’s underlying portfolio holdings. A loss of liquidity for Fund shares could lead to differences between the market price of the Fund shares and the underlying value of the Fund shares.
Focused Portfolio Risk. Funds that invest in a limited number of companies may have more risk because changes in the value of a single security may have a more significant effect, either negative or positive, on the value of the Fund’s total portfolio.
Financial Services Risk. Risks of investing in the financial services sector include: (1) systemic risk: factors outside the control of a particular financial institution may adversely affect the ability of the financial institution to operate normally or may impair its financial condition; (2) regulatory actions: financial services companies may suffer setbacks if regulators change the rules under which they operate; (3) changes in interest rates: unstable and/or rising interest rates may have a disproportionate effect on companies in the financial services sector; (4) non-diversified loan portfolios: financial services companies may have concentrated portfolios that make them vulnerable to economic conditions that affect an industry; (5) credit: financial services companies may have exposure to investments or agreements that may lead to losses; and (6) competition: the financial services sector has become increasingly competitive.
Foreign Country Risk. Securities of foreign companies (including Depositary Receipts) may be subject to greater risk, as foreign economies may not be as strong or diversified, foreign political systems may not be as stable and foreign financial reporting standards may not be as rigorous as they are in the United States. There may also be less information publicly available regarding the non-U.S. issuers and their securities. These securities may be less liquid (and, in some cases, may be illiquid) and could be harder to value than more liquid securities.
Headline Risk. The Fund may invest in a company when the company becomes the center of controversy after receiving adverse media attention concerning its operations, long-term prospects, management, or for other reasons. While Davis Advisors researches companies subject to such contingencies, it cannot be correct every time, and the company’s stock may never recover or may become worthless.
Large-Capitalization Companies Risk. Companies with $10 billion or more in market capitalization are considered by the Adviser to be large-capitalization companies. Large-capitalization companies generally experience slower rates of growth in earnings per share than do mid- and small-capitalization companies.
Manager Risk. Poor security selection or focus on securities in a particular sector, category, or group of companies may cause the Fund to underperform relevant benchmarks or other funds with a similar investment objective. Even if the Adviser implements the intended investment strategies, the implementation of the strategies may be unsuccessful in achieving the Fund’s investment objective.
Authorized Participant Concentration Risk. Only an Authorized Participant (“AP”) (as defined in the “Creations and Redemptions” section of the Fund’s prospectus) may engage in creation and/or redemption transactions directly with the Fund. The Fund has a limited number of financial intermediaries that act as APs. To the extent that these intermediaries exit the
Prospectus | Davis Fundamental ETF Trust | 4
business or are unable or unwilling to proceed with creation and/or redemption orders with respect to the Fund and no other AP is able to step forward to create or redeem Creation Units, Fund shares may trade at a discount to net asset value (“NAV”) and could face delisting. There are a limited number of financial institutions that may act as APs that post collateral for certain trades on an agency basis (i.e., on behalf of other market participants). To the extent that those APs exit the business or are unable to process creation and/or redemption orders and no other AP is able to step forward to do so, there may be a significantly diminished trading market for the ETF’s shares. In addition, please note that this could in turn lead to differences between the market price of the ETF’s shares and the underlying value of those shares.
Cybersecurity Risk. A cybersecurity breach may disrupt the business operations of the Fund or its service providers. A breach may allow an unauthorized party to gain access to Fund assets, customer data or proprietary information, or cause the Fund and/or its service providers to suffer data corruption or lose operational functionality.
Depositary Receipts Risk. Depositary Receipts, consisting of American Depositary Receipts, European Depositary Receipts, and Global Depositary Receipts, are certificates evidencing ownership of shares of a foreign issuer. Depositary Receipts are subject to many of the risks associated with investing directly in foreign securities. Depositary Receipts may trade at a discount, or a premium, to the underlying security and may be less liquid than the underlying securities listed on an exchange.
Fees and Expenses Risk. The Fund may not earn enough through income and capital appreciation to offset the operating expenses of the Fund. All mutual funds incur operating fees and expenses. Fees and expenses reduce the return that a shareholder may earn by investing in a fund, even when a fund has favorable performance. A low-return environment, or a bear market, increases the risk that a shareholder may lose money.
Foreign Currency Risk. The change in value of a foreign currency against the U.S. dollar will result in a change in the U.S. dollar value of securities denominated in that foreign currency. For example, when the Fund holds a security that is denominated in a foreign currency, a decline of that foreign currency against the U.S. dollar would generally cause the value of the Fund’s shares to decline.
Mid- and Small-Capitalization Companies Risk. Companies with less than $10 billion in market capitalization are considered by the Adviser to be mid- or small-capitalization companies. Mid- and small-capitalization companies typically have more limited product lines, markets, and financial resources than larger companies and their securities may trade less frequently and in more limited volume than those of larger, more mature companies.
Shareholder Concentration Risk. From time to time, a relatively large percentage (over 20%) of the Fund’s shares may be held by related shareholders. A large redemption by one or more of such shareholders may: (1) reduce the Fund’s liquidity, (2) increase the Fund’s transactions and transaction costs, (3) result in substantial capital gains distributions for shareholders, and (4) increase the Fund’s ongoing operating expenses, which could negatively impact the remaining shareholders of the Fund.
An investment in the Fund is not a deposit of the bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.

| | Returns | Period Ending |
| Quarter | | |
| Quarter | - | |
Prospectus | Davis Fundamental ETF Trust | 5
| Average Annual Total Returns (For the periods ended December 31, 2025) | Past 1 Year | Past 5 Years | Since Inception (1/11/17) |
| Return before taxes | | | |
| Return after taxes on distributions | | | |
| Return after taxes on distributions and sale of Fund shares | | | |
| S&P 500 Index reflects no deduction for fees, expenses or taxes | | | |
Management
Investment Adviser. Davis Selected Advisers, L.P. serves as the Fund’s investment adviser.
Sub-Adviser. Davis Selected Advisers–NY, Inc., a wholly owned subsidiary of the Adviser, serves as the Fund’s sub-adviser.
Portfolio Managers. As of the date of this prospectus, the Portfolio Managers listed below are jointly
and primarily responsible for the day-to-day management of the Fund’s portfolio.
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Portfolio Managers
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Experience with this Fund
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Primary Title with Investment Adviser or Sub-Adviser
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Christopher Davis
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Since January 2017
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Chairman, Davis Selected Advisers, L.P.
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Danton Goei
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Since January 2017
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Vice President, Davis Selected Advisers–NY, Inc.
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Purchase and Sale of Fund Shares
The Fund is an actively managed ETF. Individual shares of the Fund are listed on a
national securities exchange. Individual shares may only be bought and sold in the secondary market through a broker or dealer
at a market price. As the price of Fund shares is based on the market price, and because ETF shares trade at a market price
rather than at NAV, shares may trade at a price greater than NAV (a premium) or less than NAV (a discount). An investor may
incur costs attributable to the difference between the highest price a buyer is willing to pay to purchase shares of a Fund (the
bid) and the lowest price a seller is willing to accept for shares of a Fund (the ask) when buying or selling shares in the secondary
market (the bid-ask spread). The Fund will only issue or redeem shares that have been aggregated into blocks of 25,000 shares or multiples thereof (“Creation Units”) to APs who have entered into agreements with the Fund’s distributor. The Fund generally will issue or redeem Creations Units in return for a designated portfolio of securities (and an amount of cash) the Fund
specifies each day. Current information regarding the net asset value, market price, premium and/or discount, and bid-ask
spreads on a Fund can be obtained at www.davisetfs.com.
For important information about the purchase and sale of Fund shares and tax information, please see the “Buying and Selling Shares” section of the Fund’s prospectus.
Tax Information
If the Fund earns income or realizes capital gains, it intends to make distributions
that may be taxed as ordinary income, qualified dividend income or capital gains by federal, state and local authorities.
Payments to Broker-Dealers and Other Financial Intermediaries
If you purchase the Fund through a broker-dealer or other financial intermediary (such
as a bank), the Fund and its related companies may pay the intermediary for the sale of Fund shares and related services.
These payments may create a conflict of interest by influencing the broker-dealer or other intermediary and your salesperson
to recommend the Fund over another investment. Ask your salesperson or visit your financial intermediary’s website for more information.
Prospectus | Davis Fundamental ETF Trust | 6
The Fund seeks long-term growth of capital.
This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.
| Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) | |
| Management Fees | |
| Other Expenses | |
| Total Annual Fund Operating Expenses | |
| Less Fee Waiver and/or Expense Reimbursement* | |
| Total Annual Fund Operating Expenses After Fee Waivers and/or Expense Reimbursements | |
The Adviser (as defined below) is contractually committed to waive fees and/or reimburse the Fund’s expenses to the extent necessary to cap total annual fund operating expenses at 0.75%. For purposes of this expense cap, operating expenses do not include foreign tax reclaim filing expenses. The Adviser is obligated to continue the expense cap through March 1, 2027 . The expense cap cannot be modified prior to this date without the consent of the Board of Trustees. After that date, there is no assurance that the Adviser will continue to cap expenses. The Adviser may not recoup any of the operating expenses it has reimbursed to the Fund.
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1 Year
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3 Years
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5 Years
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10 Years
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DINT
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$ |
$ |
$ |
$ |
The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 18 % of the average value of its portfolio.
The Fund is an actively managed exchange-traded fund (“ETF”). Davis Selected Advisers, L.P. (“Davis Advisors” or the “Adviser”), the Fund’s investment adviser, uses the Davis Investment Discipline to invest the Fund’s portfolio principally in common stocks (including indirect holdings of common stock through Depositary Receipts (as defined below)) issued by foreign companies, including countries with developed or emerging markets. The Fund may invest in large, medium or small companies without regard to market capitalization. The Fund will invest significantly (at least 40% of total assets under normal market conditions and at least 30% of total assets if market conditions are not deemed favorable) in issuers (1) organized or located outside of the U. S.; (2) whose primary trading market is located outside the U.S.; or (3) doing a substantial amount of business outside the U.S., which the Fund considers to be a company that derives at least 50% of its revenue from business outside the U.S. or has at least 50% of its assets outside the U.S. Under normal market conditions, the Fund will invest in issuers representing at least three different countries. These non-U.S. company investments may include European Depositary Receipts (“EDRs”), American Depositary Receipts (“ADRs”), and Global Depositary Receipts (“GDRs” and together with EDRs and ADRs, “Depositary Receipts”). Depositary Receipts are receipts that represent ownership of shares of a non-U.S. issuer held in trust by a bank or similar financial institution.
Davis Investment Discipline. Davis Advisors manages equity funds using the Davis Investment Discipline. Davis
Advisors conducts extensive research to try to identify businesses that possess characteristics
that Davis Advisors believes foster the creation of long-term value, such as proven management, a durable franchise and business
model, and sustainable competitive advantages. Davis Advisors aims to invest in such businesses when they are trading
at discounts to their intrinsic worth. Davis Advisors emphasizes individual stock selection and believes that the ability to evaluate
management is critical. Davis Advisors routinely visits managers at their places of business in order to gain insight into
the relative value of different businesses. Such research, however rigorous, involves predictions and forecasts that are inherently
uncertain. After determining which companies Davis Advisors believes the Fund should own, Davis Advisors then turns its
analysis to determining the intrinsic value of those companies’ equity securities. Davis Advisors seeks companies whose equity securities can be purchased at a discount from Davis Advisors’ estimate of the company’s intrinsic value based upon fundamental analysis of cash flows, assets and liabilities, and other criteria that Davis Advisors deems to be material on a company-by-company basis. Davis Advisors’
Prospectus | Davis Fundamental ETF Trust | 7
goal is to invest in companies for the long term (ideally, five years or longer, although
this goal may not be met). Davis Advisors considers selling a company’s equity securities if the securities’ market price exceeds Davis Advisors’ estimates of intrinsic value, if the ratio of the risks and rewards of continuing to own the company’s equity securities is no longer attractive, to raise cash to purchase a more attractive investment opportunity, to satisfy net
redemptions, or for other purposes.
Principal Risks of Investing in the Fund
The principal risks of investing in the Fund are:
Stock Market Risk. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices, including the possibility of sharp declines.
Common Stock Risk. Common stock represents an ownership position in a company. An adverse event may have a negative impact on a company and could result in a decline in the price of its common stock. Common stock is generally subordinate to an issuer’s other securities, including preferred, convertible, and debt securities.
Market Trading Risk. The Fund is subject to a number of market trading risks, which include the possibility of an inactive market for Fund shares, losses from trading in secondary markets, periods of high volatility and disruptions in the creation/redemption process. ONE OR MORE OF THESE FACTORS, AMONG OTHERS, COULD LEAD TO THE FUND’S SHARES TRADING AT A PREMIUM OR DISCOUNT TO NAV. The Fund’s market price may vary from the value of the Fund’s underlying portfolio holdings, particularly in times of market stress. This difference may be reflected as a spread between the bid and ask prices for the Fund shares during the day or a premium or discount in the closing market price of the Fund when compared to the NAV. An investor may pay significantly more or receive significantly less than the underlying value of the Fund shares bought or sold.
Exchange-Traded Fund Risk. The Fund is an actively managed exchange-traded fund and trades like common stock on an exchange. The Fund is subject to the risks of owning the underlying securities, as well as the risks of owning an exchange-traded fund generally. The management fees of an actively managed exchange-traded fund are generally higher and can increase the Fund’s expenses. The market for the Fund’s shares may become less liquid in response to the deteriorating liquidity in the market for the Fund’s underlying portfolio holdings. A loss of liquidity for Fund shares could lead to differences between the market price of the Fund shares and the underlying value of the Fund shares.
Foreign Country Risk. Securities of foreign companies (including Depositary Receipts) may be subject to greater risk, as foreign economies may not be as strong or diversified, foreign political systems may not be as stable and foreign financial reporting standards may not be as rigorous as they are in the United States. There may also be less information publicly available regarding the non-U.S. issuers and their securities. These securities may be less liquid (and, in some cases, may be illiquid) and could be harder to value than more liquid securities.
Exposure to Industry or Sector Risk. Subject to the Fund’s investment limitations, the Fund may have significant exposure to a particular industry or sector. Such exposure may cause the Fund to be more impacted by risks relating to and developments affecting the industry or sector, and thus its net asset value may be more volatile than a fund without such levels of exposure. For example, if the Fund has significant exposure in a particular industry, then economic, regulatory, or other issues that negatively affect that industry may have a greater impact on the Fund than on a fund that is more diversified.
China Risk – Generally. Investment in Chinese securities may subject the Fund to risks that are specific to China. China may be subject to significant amounts of instability, including, but not limited to, economic, political, and social instability. China’s economy may differ from the U.S. economy in certain respects, including, but not limited to, general development, level of government involvement, wealth distribution, and structure.
The Fund may invest in securities issued by variable interest entities (“VIEs”), which are subject to the investment risks associated with the underlying Chinese operating company. A VIE enters into service contracts and other contracts with the Chinese operating company, which provide the VIE with exposure to the company. Although the VIE has no equity ownership of the Chinese operating company, the contractual arrangements permit the VIE to consolidate the Chinese operating company into its financial statements. Intervention by the Chinese government with respect to VIEs could significantly affect the Chinese operating company’s performance and the enforceability of the VIE’s contractual arrangements with the Chinese company.
Headline Risk. The Fund may invest in a company when the company becomes the center of controversy after receiving adverse media attention concerning its operations, long-term prospects, management, or for other reasons. While Davis Advisors researches companies subject to such contingencies, it cannot be correct every time, and the company’s stock may never recover or may become worthless.
Foreign Market Risk. Because certain foreign holdings of the Fund may trade in a market that is closed when the market in which the Fund’s shares are listed is open, there may be changes between the last quote of the foreign holding from its closed foreign market and the value of such security during the Fund’s domestic trading day. This in turn could lead to differences between the market price of the Fund’s shares and the underlying value of those shares.
Prospectus | Davis Fundamental ETF Trust | 8
Large-Capitalization Companies Risk. Companies with $10 billion or more in market capitalization are considered by the Adviser to be large-capitalization companies. Large-capitalization companies generally experience slower rates of growth in earnings per share than do mid- and small-capitalization companies.
Manager Risk. Poor security selection or focus on securities in a particular sector, category, or group of companies may cause the Fund to underperform relevant benchmarks or other funds with a similar investment objective. Even if the Adviser implements the intended investment strategies, the implementation of the strategies may be unsuccessful in achieving the Fund’s investment objective.
Authorized Participant Concentration Risk. Only an Authorized Participant (“AP”) (as defined in the “Creations and Redemptions” section of the Fund’s prospectus) may engage in creation and/or redemption transactions directly with the Fund. The Fund has a limited number of financial intermediaries that act as APs. To the extent that these intermediaries exit the business or are unable or unwilling to proceed with creation and/or redemption orders with respect to the Fund and no other AP is able to step forward to create or redeem Creation Units, Fund shares may trade at a discount to net asset value (“NAV”) and could face delisting. There are a limited number of financial institutions that may act as APs that post collateral for certain trades on an agency basis (i.e., on behalf of other market participants). To the extent that those APs exit the business or are unable to process creation and/or redemption orders and no other AP is able to step forward to do so, there may be a significantly diminished trading market for the ETF’s shares. In addition, please note that this could in turn lead to differences between the market price of the ETF’s shares and the underlying value of those shares.
Cybersecurity Risk. A cybersecurity breach may disrupt the business operations of the Fund or its service providers. A breach may allow an unauthorized party to gain access to Fund assets, customer data or proprietary information, or cause the Fund and/or its service providers to suffer data corruption or lose operational functionality.
Emerging Market Risk. Securities of issuers in emerging and developing markets may offer special investment opportunities, but present risks relating to political, economic, or regulatory conditions not found in more mature markets, such as government controls on foreign investments, government restrictions on the transfer of securities, and less developed trading markets, exchanges, reporting standards, and legal and accounting systems. These securities may be more volatile and less liquid, which may also make them more difficult to value than securities in countries with developed economies.
Depositary Receipts Risk. Depositary Receipts, consisting of American Depositary Receipts, European Depositary Receipts, and Global Depositary Receipts, are certificates evidencing ownership of shares of a foreign issuer. Depositary Receipts are subject to many of the risks associated with investing directly in foreign securities. Depositary Receipts may trade at a discount, or a premium, to the underlying security and may be less liquid than the underlying securities listed on an exchange.
Fees and Expenses Risk. The Fund may not earn enough through income and capital appreciation to offset the operating expenses of the Fund. All mutual funds incur operating fees and expenses. Fees and expenses reduce the return that a shareholder may earn by investing in a fund, even when a fund has favorable performance. A low-return environment, or a bear market, increases the risk that a shareholder may lose money.
Foreign Currency Risk. The change in value of a foreign currency against the U.S. dollar will result in a change in the U.S. dollar value of securities denominated in that foreign currency. For example, when the Fund holds a security that is denominated in a foreign currency, a decline of that foreign currency against the U.S. dollar would generally cause the value of the Fund’s shares to decline.
Mid- and Small-Capitalization Companies Risk. Companies with less than $10 billion in market capitalization are considered by the Adviser to be mid- or small-capitalization companies. Mid- and small-capitalization companies typically have more limited product lines, markets, and financial resources than larger companies and their securities may trade less frequently and in more limited volume than those of larger, more mature companies.
Shareholder Concentration Risk. From time to time, a relatively large percentage (over 20%) of the Fund’s shares may be held by related shareholders. A large redemption by one or more of such shareholders may: (1) reduce the Fund’s liquidity, (2) increase the Fund’s transactions and transaction costs, (3) result in substantial capital gains distributions for shareholders, and (4) increase the Fund’s ongoing operating expenses, which could negatively impact the remaining shareholders of the Fund.
An investment in the Fund is not a deposit of the bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.
Prospectus | Davis Fundamental ETF Trust | 9

| | Returns | Period Ending |
| Quarter | | |
| Quarter | - | |
| Average Annual Total Returns (For the periods ended December 31, 2025) | Past 1 Year | Past 5 Years | Since Inception (3/1/18) |
| Return before taxes | | | |
| Return after taxes on distributions | | | |
| Return after taxes on distributions and sale of Fund shares | | | |
| MSCI ACWI (All Country World Index) ex U.S. reflects no deduction for fees, expenses or taxes | | | |
Management
Investment Adviser. Davis Selected Advisers, L.P. serves as the Fund’s investment adviser.
Sub-Adviser. Davis Selected Advisers–NY, Inc., a wholly owned subsidiary of the Adviser, serves as the Fund’s sub-adviser.
Portfolio Manager. As of the date of this prospectus, the Portfolio Manager listed below is primarily
responsible for the day-to-day management of the Fund’s portfolio.
|
Portfolio Manager
|
Experience with this Fund
|
Primary Title with Investment Adviser or Sub-Adviser
|
|
Danton Goei
|
Since March 2018
|
Vice President, Davis Selected Advisers–NY, Inc.
|
Purchase and Sale of Fund Shares
The Fund is an actively managed ETF. Individual shares of the Fund are listed on a
national securities exchange. Individual shares may only be bought and sold in the secondary market through a broker or dealer
at a market price. As the price of Fund shares is based on the market price, and because ETF shares trade at a market price
rather than at NAV, shares may trade at a price greater than NAV (a premium) or less than NAV (a discount). An investor may
incur costs attributable to the difference between the highest price a buyer is willing to pay to purchase shares of a Fund (the
bid) and the lowest price a seller is willing to accept for shares of a Fund (the ask) when buying or selling shares in the secondary
market (the bid-ask spread). The Fund will only issue or redeem shares that have been aggregated into blocks of 25,000 shares or multiples thereof (“Creation Units”) to APs who have entered into agreements with the Fund’s distributor. The Fund generally will issue or redeem Creations Units in return for a designated portfolio of securities (and an amount of cash) the Fund
specifies each day. Current information regarding the net asset value, market price, premium and/or discount, and bid-ask
spreads on a Fund can be obtained at www.davisetfs.com.
For important information about the purchase and sale of Fund shares and tax information, please see the “Buying and Selling Shares” section of the Fund’s prospectus.
Tax Information
If the Fund earns income or realizes capital gains, it intends to make distributions
that may be taxed as ordinary income, qualified dividend income or capital gains by federal, state and local authorities.
Payments to Broker-Dealers and Other Financial Intermediaries
If you purchase the Fund through a broker-dealer or other financial intermediary (such
as a bank), the Fund and its related companies may pay the intermediary for the sale of Fund shares and related services.
These payments may create a conflict of interest by influencing the broker-dealer or other intermediary and your salesperson
to recommend the Fund over another investment. Ask your salesperson or visit your financial intermediary’s website for more information.
Prospectus | Davis Fundamental ETF Trust | 10
The Fund seeks long-term growth of capital.
This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.
| Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) | |
| Management Fees | |
| Other Expenses | |
| Total Annual Fund Operating Expenses | |
| Less Fee Waiver and/or Expense Reimbursement* | |
| Total Annual Fund Operating Expenses After Fee Waivers and/or Expense Reimbursements | |
The Adviser (as defined below) is contractually committed to waive fees and/or reimburse the Fund’s expenses to the extent necessary to cap total annual fund operating expenses at 0.65%. For purposes of this expense cap, operating expenses do not include foreign tax reclaim filing expenses. The Adviser is obligated to continue the expense cap through March 1, 2027 . The expense cap cannot be modified prior to this date without the consent of the Board of Trustees. After that date, there is no assurance that the Adviser will continue to cap expenses. The Adviser may not recoup any of the operating expenses it has reimbursed to the Fund.
|
|
1 Year
|
3 Years
|
5 Years
|
10 Years
|
|
DWLD
|
$ |
$ |
$ |
$ |
The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 19 % of the average value of its portfolio.
The Fund is an actively managed exchange-traded fund (“ETF”). Davis Selected Advisers, L.P. (“Davis Advisors” or the “Adviser”), the Fund’s investment adviser, uses the Davis Investment Discipline to invest the Fund’s portfolio principally in common stocks (including indirect holdings of common stock through Depositary Receipts (as defined below)) issued by both United States and foreign companies, including countries with developed or emerging markets. The Fund may invest in large, medium or small companies without regard to market capitalization. The Fund will invest significantly (at least 40% of total assets under normal market conditions and at least 30% of total assets if market conditions are not deemed favorable) in issuers (1) organized or located outside of the U. S.; (2) whose primary trading market is located outside the U.S.; or (3) doing a substantial amount of business outside the U.S., which the Fund considers to be a company that derives at least 50% of its revenue from business outside the U.S. or has at least 50% of its assets outside the U.S. Under normal market conditions, the Fund will invest in issuers representing at least three different countries. These non-U.S. company investments may include European Depositary Receipts (“EDRs”), American Depositary Receipts (“ADRs”), and Global Depositary Receipts (“GDRs” and together with EDRs and ADRs, “Depositary Receipts”). Depositary Receipts are receipts that represent ownership of shares of a non-U.S. issuer held in trust by a bank or similar financial institution.
Davis Investment Discipline. Davis Advisors manages equity funds using the Davis Investment Discipline. Davis
Advisors conducts extensive research to try to identify businesses that possess characteristics
that Davis Advisors believes foster the creation of long-term value, such as proven management, a durable franchise and business
model, and sustainable competitive advantages. Davis Advisors aims to invest in such businesses when they are trading
at discounts to their intrinsic worth. Davis Advisors emphasizes individual stock selection and believes that the ability to evaluate
management is critical. Davis Advisors routinely visits managers at their places of business in order to gain insight into
the relative value of different businesses. Such research, however rigorous, involves predictions and forecasts that are inherently
uncertain. After determining which companies Davis Advisors believes the Fund should own, Davis Advisors then turns its
analysis to determining the intrinsic value of those companies’ equity securities. Davis Advisors seeks companies whose equity securities can be purchased at a discount from Davis Advisors’ estimate of the company’s intrinsic value based upon fundamental analysis of cash flows, assets and liabilities, and other criteria that Davis Advisors deems to be material on a company-by-company basis. Davis Advisors’
Prospectus | Davis Fundamental ETF Trust | 11
goal is to invest in companies for the long term (ideally, five years or longer, although
this goal may not be met). Davis Advisors considers selling a company’s equity securities if the securities’ market price exceeds Davis Advisors’ estimates of intrinsic value, if the ratio of the risks and rewards of continuing to own the company’s equity securities is no longer attractive, to raise cash to purchase a more attractive investment opportunity, to satisfy net
redemptions, or for other purposes.
Principal Risks of Investing in the Fund
The principal risks of investing in the Fund are:
Stock Market Risk. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices, including the possibility of sharp declines.
Common Stock Risk. Common stock represents an ownership position in a company. An adverse event may have a negative impact on a company and could result in a decline in the price of its common stock. Common stock is generally subordinate to an issuer’s other securities, including preferred, convertible, and debt securities.
Market Trading Risk. The Fund is subject to a number of market trading risks, which include the possibility of an inactive market for Fund shares, losses from trading in secondary markets, periods of high volatility and disruptions in the creation/redemption process. ONE OR MORE OF THESE FACTORS, AMONG OTHERS, COULD LEAD TO THE FUND’S SHARES TRADING AT A PREMIUM OR DISCOUNT TO NAV. The Fund’s market price may vary from the value of the Fund’s underlying portfolio holdings, particularly in times of market stress. This difference may be reflected as a spread between the bid and ask prices for the Fund shares during the day or a premium or discount in the closing market price of the Fund when compared to the NAV. An investor may pay significantly more or receive significantly less than the underlying value of the Fund shares bought or sold.
Exchange-Traded Fund Risk. The Fund is an actively managed exchange-traded fund and trades like common stock on an exchange. The Fund is subject to the risks of owning the underlying securities, as well as the risks of owning an exchange-traded fund generally. The management fees of an actively managed exchange-traded fund are generally higher and can increase the Fund’s expenses. The market for the Fund’s shares may become less liquid in response to the deteriorating liquidity in the market for the Fund’s underlying portfolio holdings. A loss of liquidity for Fund shares could lead to differences between the market price of the Fund shares and the underlying value of the Fund shares.
Foreign Country Risk. Securities of foreign companies (including Depositary Receipts) may be subject to greater risk, as foreign economies may not be as strong or diversified, foreign political systems may not be as stable and foreign financial reporting standards may not be as rigorous as they are in the United States. There may also be less information publicly available regarding the non-U.S. issuers and their securities. These securities may be less liquid (and, in some cases, may be illiquid) and could be harder to value than more liquid securities.
Exposure to Industry or Sector Risk. Subject to the Fund’s investment limitations, the Fund may have significant exposure to a particular industry or sector. Such exposure may cause the Fund to be more impacted by risks relating to and developments affecting the industry or sector, and thus its net asset value may be more volatile than a fund without such levels of exposure. For example, if the Fund has significant exposure in a particular industry, then economic, regulatory, or other issues that negatively affect that industry may have a greater impact on the Fund than on a fund that is more diversified.
China Risk – Generally. Investment in Chinese securities may subject the Fund to risks that are specific to China. China may be subject to significant amounts of instability, including, but not limited to, economic, political, and social instability. China’s economy may differ from the U.S. economy in certain respects, including, but not limited to, general development, level of government involvement, wealth distribution, and structure.
The Fund may invest in securities issued by variable interest entities (“VIEs”), which are subject to the investment risks associated with the underlying Chinese operating company. A VIE enters into service contracts and other contracts with the Chinese operating company, which provide the VIE with exposure to the company. Although the VIE has no equity ownership of the Chinese operating company, the contractual arrangements permit the VIE to consolidate the Chinese operating company into its financial statements. Intervention by the Chinese government with respect to VIEs could significantly affect the Chinese operating company’s performance and the enforceability of the VIE’s contractual arrangements with the Chinese company.
Headline Risk. The Fund may invest in a company when the company becomes the center of controversy after receiving adverse media attention concerning its operations, long-term prospects, management, or for other reasons. While Davis Advisors researches companies subject to such contingencies, it cannot be correct every time, and the company’s stock may never recover or may become worthless.
Foreign Market Risk. Because certain foreign holdings of the Fund may trade in a market that is closed when the market in which the Fund’s shares are listed is open, there may be changes between the last quote of the foreign holding from its closed foreign market and the value of such security during the Fund’s domestic trading day. This in turn could lead to differences between the market price of the Fund’s shares and the underlying value of those shares.
Prospectus | Davis Fundamental ETF Trust | 12
Large-Capitalization Companies Risk. Companies with $10 billion or more in market capitalization are considered by the Adviser to be large-capitalization companies. Large-capitalization companies generally experience slower rates of growth in earnings per share than do mid- and small-capitalization companies.
Manager Risk. Poor security selection or focus on securities in a particular sector, category, or group of companies may cause the Fund to underperform relevant benchmarks or other funds with a similar investment objective. Even if the Adviser implements the intended investment strategies, the implementation of the strategies may be unsuccessful in achieving the Fund’s investment objective.
Authorized Participant Concentration Risk. Only an Authorized Participant (“AP”) (as defined in the “Creations and Redemptions” section of the Fund’s prospectus) may engage in creation and/or redemption transactions directly with the Fund. The Fund has a limited number of financial intermediaries that act as APs. To the extent that these intermediaries exit the business or are unable or unwilling to proceed with creation and/or redemption orders with respect to the Fund and no other AP is able to step forward to create or redeem Creation Units, Fund shares may trade at a discount to net asset value (“NAV”) and could face delisting. There are a limited number of financial institutions that may act as APs that post collateral for certain trades on an agency basis (i.e., on behalf of other market participants). To the extent that those APs exit the business or are unable to process creation and/or redemption orders and no other AP is able to step forward to do so, there may be a significantly diminished trading market for the ETF’s shares. In addition, please note that this could in turn lead to differences between the market price of the ETF’s shares and the underlying value of those shares.
Cybersecurity Risk. A cybersecurity breach may disrupt the business operations of the Fund or its service providers. A breach may allow an unauthorized party to gain access to Fund assets, customer data or proprietary information, or cause the Fund and/or its service providers to suffer data corruption or lose operational functionality.
Emerging Market Risk. Securities of issuers in emerging and developing markets may offer special investment opportunities, but present risks relating to political, economic, or regulatory conditions not found in more mature markets, such as government controls on foreign investments, government restrictions on the transfer of securities, and less developed trading markets, exchanges, reporting standards, and legal and accounting systems. These securities may be more volatile and less liquid, which may also make them more difficult to value than securities in countries with developed economies.
Depositary Receipts Risk. Depositary Receipts, consisting of American Depositary Receipts, European Depositary Receipts, and Global Depositary Receipts, are certificates evidencing ownership of shares of a foreign issuer. Depositary Receipts are subject to many of the risks associated with investing directly in foreign securities. Depositary Receipts may trade at a discount, or a premium, to the underlying security and may be less liquid than the underlying securities listed on an exchange.
Fees and Expenses Risk. The Fund may not earn enough through income and capital appreciation to offset the operating expenses of the Fund. All mutual funds incur operating fees and expenses. Fees and expenses reduce the return that a shareholder may earn by investing in a fund, even when a fund has favorable performance. A low-return environment, or a bear market, increases the risk that a shareholder may lose money.
Foreign Currency Risk. The change in value of a foreign currency against the U.S. dollar will result in a change in the U.S. dollar value of securities denominated in that foreign currency. For example, when the Fund holds a security that is denominated in a foreign currency, a decline of that foreign currency against the U.S. dollar would generally cause the value of the Fund’s shares to decline.
Mid- and Small-Capitalization Companies Risk. Companies with less than $10 billion in market capitalization are considered by the Adviser to be mid- or small-capitalization companies. Mid- and small-capitalization companies typically have more limited product lines, markets, and financial resources than larger companies and their securities may trade less frequently and in more limited volume than those of larger, more mature companies.
Shareholder Concentration Risk. From time to time, a relatively large percentage (over 20%) of the Fund’s shares may be held by related shareholders. A large redemption by one or more of such shareholders may: (1) reduce the Fund’s liquidity, (2) increase the Fund’s transactions and transaction costs, (3) result in substantial capital gains distributions for shareholders, and (4) increase the Fund’s ongoing operating expenses, which could negatively impact the remaining shareholders of the Fund.
An investment in the Fund is not a deposit of the bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.
Prospectus | Davis Fundamental ETF Trust | 13

| | Returns | Period Ending |
| Quarter | | |
| Quarter | - | |
| Average Annual Total Returns (For the periods ended December 31, 2025) | Past 1 Year | Past 5 Years | Since Inception (1/11/17) |
| Return before taxes | | | |
| Return after taxes on distributions | | | |
| Return after taxes on distributions and sale of Fund shares | | | |
| MSCI ACWI (All Country World Index) reflects no deduction for fees, expenses or taxes | | | |
Management
Investment Adviser. Davis Selected Advisers, L.P. serves as the Fund’s investment adviser.
Sub-Adviser. Davis Selected Advisers–NY, Inc., a wholly owned subsidiary of the Adviser, serves as the Fund’s sub-adviser.
Portfolio Manager. As of the date of this prospectus, the Portfolio Manager listed below is primarily
responsible for the day-to-day management of the Fund’s portfolio.
|
Portfolio Manager
|
Experience with this Fund
|
Primary Title with Investment Adviser or Sub-Adviser
|
|
Danton Goei
|
Since January 2017
|
Vice President, Davis Selected Advisers–NY, Inc.
|
Purchase and Sale of Fund Shares
The Fund is an actively managed ETF. Individual shares of the Fund are listed on a
national securities exchange. Individual shares may only be bought and sold in the secondary market through a broker or dealer
at a market price. As the price of Fund shares is based on the market price, and because ETF shares trade at a market price
rather than at NAV, shares may trade at a price greater than NAV (a premium) or less than NAV (a discount). An investor may
incur costs attributable to the difference between the highest price a buyer is willing to pay to purchase shares of a Fund (the
bid) and the lowest price a seller is willing to accept for shares of a Fund (the ask) when buying or selling shares in the secondary
market (the bid-ask spread). The Fund will only issue or redeem shares that have been aggregated into blocks of 25,000 shares or multiples thereof (“Creation Units”) to APs who have entered into agreements with the Fund’s distributor. The Fund generally will issue or redeem Creations Units in return for a designated portfolio of securities (and an amount of cash) the Fund
specifies each day. Current information regarding the net asset value, market price, premium and/or discount, and bid-ask
spreads on a Fund can be obtained at www.davisetfs.com.
For important information about the purchase and sale of Fund shares and tax information, please see the “Buying and Selling Shares” section of the Fund’s prospectus.
Tax Information
If the Fund earns income or realizes capital gains, it intends to make distributions
that may be taxed as ordinary income, qualified dividend income or capital gains by federal, state and local authorities.
Payments to Broker-Dealers and Other Financial Intermediaries
If you purchase the Fund through a broker-dealer or other financial intermediary (such
as a bank), the Fund and its related companies may pay the intermediary for the sale of Fund shares and related services.
These payments may create a conflict of interest by influencing the broker-dealer or other intermediary and your salesperson
to recommend the Fund over another investment. Ask your salesperson or visit your financial intermediary’s website for more information.
Prospectus | Davis Fundamental ETF Trust | 14
The Fund seeks long-term growth of capital.
This table describes the fees and expenses that you may pay if you buy, hold, and sell shares of the Fund. You may pay other fees, such as brokerage commissions and other fees to financial intermediaries, which are not reflected in the tables and examples below.
| Annual Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment) | |
| Management Fees | |
| Other Expenses | |
| Total Annual Fund Operating Expenses | |
| Less Fee Waiver and/or Expense Reimbursement* | |
| Total Annual Fund Operating Expenses After Fee Waivers and/or Expense Reimbursements | |
The Adviser (as defined below) is contractually committed to waive fees and/or reimburse the Fund’s expenses to the extent necessary to cap total annual fund operating expenses at 0.65%. For purposes of this expense cap, operating expenses do not include foreign tax reclaim filing expenses. The Adviser is obligated to continue the expense cap through March 1, 2027 . The expense cap cannot be modified prior to this date without the consent of the Board of Trustees. After that date, there is no assurance that the Adviser will continue to cap expenses. The Adviser may not recoup any of the operating expenses it has reimbursed to the Fund.
|
|
1 Year
|
3 Years
|
5 Years
|
10 Years
|
|
DFNL
|
$ |
$ |
$ |
$ |
The Fund pays transaction costs, such as commissions, when it buys and sells securities (or “turns over” its portfolio). A higher portfolio turnover rate may indicate higher transaction costs and may result in higher taxes when Fund shares are held in a taxable account. These costs, which are not reflected in annual fund operating expenses or in the example, affect the Fund’s performance. During the most recent fiscal year, the Fund’s portfolio turnover rate was 1 % of the average value of its portfolio.
The Fund is an actively managed exchange-traded fund (“ETF”). Davis Selected Advisers, L.P. (“Davis Advisors” or the “Adviser”), the Fund’s investment adviser, uses the Davis Investment Discipline to invest, under normal market conditions, at least 80% of the Fund’s net assets plus any borrowings for investment purposes in securities issued by companies principally engaged in the financial services sector. The Fund is non- diversified and, therefore, is allowed to focus its investments in fewer companies than a fund that is required to diversify its portfolio. The Fund’s portfolio generally contains between 15 and 35 companies, although the precise number of its investments will vary over time. The Fund invests, principally, in common stocks (including indirect holdings of common stock through Depositary Receipts). The Fund may invest in large, medium or small companies without regard to market capitalization and may invest in issuers in foreign countries, including countries with developed or emerging markets. These non-U.S. company investments may include European Depositary Receipts (“EDRs”), American Depositary Receipts (“ADRs”), and Global Depositary Receipts (“GDRs” and together with EDRs and ADRs, “Depositary Receipts”). Depositary Receipts are receipts that represent ownership of shares of a non-U.S. issuer held in trust by a bank or similar financial institution.
A company is principally engaged in financial services if it owns financial services-related
assets that constitute at least 50% of the value of all of its assets, or if it derives at least 50% of its revenues from
providing financial services. Companies are classified by GICS based on their principal business activity. Revenue is a key factor in determining a firm’s principal business activity. Financial services companies include those with their principal business
activity in one of the following areas: banks, financial services, consumer finance, capital markets, insurance, and mortgage REITs.
Davis Investment Discipline. Davis Advisors manages equity funds using the Davis Investment Discipline. Davis
Advisors conducts extensive research to try to identify businesses that possess characteristics
that Davis Advisors believes foster the creation of long-term value, such as proven management, a durable franchise and business
model, and sustainable competitive advantages. Davis Advisors aims to invest in such businesses when they are trading
at discounts to their intrinsic worth. Davis Advisors emphasizes individual stock selection and believes that the ability to evaluate
management is critical. Davis Advisors routinely visits managers at their places of business in order to gain insight into
the relative value of different businesses. Such
Prospectus | Davis Fundamental ETF Trust | 15
research, however rigorous, involves predictions and forecasts that are inherently
uncertain. After determining which companies Davis Advisors believes the Fund should own, Davis Advisors then turns its
analysis to determining the intrinsic value of those companies’ equity securities. Davis Advisors seeks companies whose equity securities can be purchased at a discount from Davis Advisors’ estimate of the company’s intrinsic value based upon fundamental analysis of cash flows, assets and liabilities, and other criteria that Davis Advisors deems to be material on a company-by-company basis. Davis Advisors’ goal is to invest in companies for the long term (ideally, five years or longer, although
this goal may not be met). Davis Advisors considers selling a company’s equity securities if the securities’ market price exceeds Davis Advisors’ estimates of intrinsic value, if the ratio of the risks and rewards of continuing to own the company’s equity securities is no longer attractive, to raise cash to purchase a more attractive investment opportunity, to satisfy net
redemptions, or for other purposes.
Principal Risks of Investing in the Fund
The principal risks of investing in the Fund are:
Stock Market Risk. Stock markets tend to move in cycles, with periods of rising prices and periods of falling prices, including the possibility of sharp declines.
Common Stock Risk. Common stock represents an ownership position in a company. An adverse event may have a negative impact on a company and could result in a decline in the price of its common stock. Common stock is generally subordinate to an issuer’s other securities, including preferred, convertible, and debt securities.
Market Trading Risk. The Fund is subject to a number of market trading risks, which include the possibility of an inactive market for Fund shares, losses from trading in secondary markets, periods of high volatility and disruptions in the creation/redemption process. ONE OR MORE OF THESE FACTORS, AMONG OTHERS, COULD LEAD TO THE FUND’S SHARES TRADING AT A PREMIUM OR DISCOUNT TO NAV. The Fund’s market price may vary from the value of the Fund’s underlying portfolio holdings, particularly in times of market stress. This difference may be reflected as a spread between the bid and ask prices for the Fund shares during the day or a premium or discount in the closing market price of the Fund when compared to the NAV. An investor may pay significantly more or receive significantly less than the underlying value of the Fund shares bought or sold.
Exchange-Traded Fund Risk. The Fund is an actively managed exchange-traded fund and trades like common stock on an exchange. The Fund is subject to the risks of owning the underlying securities, as well as the risks of owning an exchange-traded fund generally. The management fees of an actively managed exchange-traded fund are generally higher and can increase the Fund’s expenses. The market for the Fund’s shares may become less liquid in response to the deteriorating liquidity in the market for the Fund’s underlying portfolio holdings. A loss of liquidity for Fund shares could lead to differences between the market price of the Fund shares and the underlying value of the Fund shares.
Financial Services Risk. Risks of investing in the financial services sector include: (1) systemic risk: factors outside the control of a particular financial institution may adversely affect the ability of the financial institution to operate normally or may impair its financial condition; (2) regulatory actions: financial services companies may suffer setbacks if regulators change the rules under which they operate; (3) changes in interest rates: unstable and/or rising interest rates may have a disproportionate effect on companies in the financial services sector; (4) non-diversified loan portfolios: financial services companies may have concentrated portfolios that make them vulnerable to economic conditions that affect an industry; (5) credit: financial services companies may have exposure to investments or agreements that may lead to losses; and (6) competition: the financial services sector has become increasingly competitive.
Credit Risk. Financial institutions are often highly leveraged and may not be able to make timely payments of interest and principal.
Interest Rate Sensitivity Risk. Interest rates may have a powerful influence on the earnings of financial institutions.
Focused Portfolio Risk. Funds that invest in a limited number of companies may have more risk because changes in the value of a single security may have a more significant effect, either negative or positive, on the value of the Fund’s total portfolio.
Headline Risk. The Fund may invest in a company when the company becomes the center of controversy after receiving adverse media attention concerning its operations, long-term prospects, management, or for other reasons. While Davis Advisors researches companies subject to such contingencies, it cannot be correct every time, and the company’s stock may never recover or may become worthless.
Foreign Country Risk. Securities of foreign companies (including Depositary Receipts) may be subject to greater risk, as foreign economies may not be as strong or diversified, foreign political systems may not be as stable and foreign financial reporting standards may not be as rigorous as they are in the United States. There may also be less information publicly available regarding the non-U.S. issuers and their securities. These securities may be less liquid (and, in some cases, may be illiquid) and could be harder to value than more liquid securities.
Prospectus | Davis Fundamental ETF Trust | 16
Large-Capitalization Companies Risk. Companies with $10 billion or more in market capitalization are considered by the Adviser to be large-capitalization companies. Large-capitalization companies generally experience slower rates of growth in earnings per share than do mid- and small-capitalization companies.
Manager Risk. Poor security selection or focus on securities in a particular sector, category, or group of companies may cause the Fund to underperform relevant benchmarks or other funds with a similar investment objective. Even if the Adviser implements the intended investment strategies, the implementation of the strategies may be unsuccessful in achieving the Fund’s investment objective.
Authorized Participant Concentration Risk. Only an Authorized Participant (“AP”) (as defined in the “Creations and Redemptions” section of the Fund’s prospectus) may engage in creation and/or redemption transactions directly with the Fund. The Fund has a limited number of financial intermediaries that act as APs. To the extent that these intermediaries exit the business or are unable or unwilling to proceed with creation and/or redemption orders with respect to the Fund and no other AP is able to step forward to create or redeem Creation Units, Fund shares may trade at a discount to net asset value (“NAV”) and could face delisting. There are a limited number of financial institutions that may act as APs that post collateral for certain trades on an agency basis (i.e., on behalf of other market participants). To the extent that those APs exit the business or are unable to process creation and/or redemption orders and no other AP is able to step forward to do so, there may be a significantly diminished trading market for the ETF’s shares. In addition, please note that this could in turn lead to differences between the market price of the ETF’s shares and the underlying value of those shares.
Cybersecurity Risk. A cybersecurity breach may disrupt the business operations of the Fund or its service providers. A breach may allow an unauthorized party to gain access to Fund assets, customer data or proprietary information, or cause the Fund and/or its service providers to suffer data corruption or lose operational functionality.
Depositary Receipts Risk. Depositary Receipts, consisting of American Depositary Receipts, European Depositary Receipts, and Global Depositary Receipts, are certificates evidencing ownership of shares of a foreign issuer. Depositary Receipts are subject to many of the risks associated with investing directly in foreign securities. Depositary Receipts may trade at a discount, or a premium, to the underlying security and may be less liquid than the underlying securities listed on an exchange.
Fees and Expenses Risk. The Fund may not earn enough through income and capital appreciation to offset the operating expenses of the Fund. All mutual funds incur operating fees and expenses. Fees and expenses reduce the return that a shareholder may earn by investing in a fund, even when a fund has favorable performance. A low-return environment, or a bear market, increases the risk that a shareholder may lose money.
Foreign Currency Risk. The change in value of a foreign currency against the U.S. dollar will result in a change in the U.S. dollar value of securities denominated in that foreign currency. For example, when the Fund holds a security that is denominated in a foreign currency, a decline of that foreign currency against the U.S. dollar would generally cause the value of the Fund’s shares to decline.
Emerging Market Risk. Securities of issuers in emerging and developing markets may offer special investment opportunities, but present risks relating to political, economic, or regulatory conditions not found in more mature markets, such as government controls on foreign investments, government restrictions on the transfer of securities, and less developed trading markets, exchanges, reporting standards, and legal and accounting systems. These securities may be more volatile and less liquid, which may also make them more difficult to value than securities in countries with developed economies.
Mid- and Small-Capitalization Companies Risk. Companies with less than $10 billion in market capitalization are considered by the Adviser to be mid- or small-capitalization companies. Mid- and small-capitalization companies typically have more limited product lines, markets, and financial resources than larger companies and their securities may trade less frequently and in more limited volume than those of larger, more mature companies.
Shareholder Concentration Risk. From time to time, a relatively large percentage (over 20%) of the Fund’s shares may be held by related shareholders. A large redemption by one or more of such shareholders may: (1) reduce the Fund’s liquidity, (2) increase the Fund’s transactions and transaction costs, (3) result in substantial capital gains distributions for shareholders, and (4) increase the Fund’s ongoing operating expenses, which could negatively impact the remaining shareholders of the Fund.
An investment in the Fund is not a deposit of the bank and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency.
Prospectus | Davis Fundamental ETF Trust | 17

| | Returns | Period Ending |
| Quarter | | |
| Quarter | - | |
| Average Annual Total Returns (For the periods ended December 31, 2025) | Past 1 Year | Past 5 Years | Since Inception (1/11/17) |
| Return before taxes | | | |
| Return after taxes on distributions | | | |
| Return after taxes on distributions and sale of Fund shares | | | |
| S&P 500 Index reflects no deduction for fees, expenses or taxes | | | |
| S&P 500 Financials Index reflects no deduction for fees, expenses or taxes | | | |
Management
Investment Adviser. Davis Selected Advisers, L.P. serves as the Fund’s investment adviser.
Sub-Adviser. Davis Selected Advisers–NY, Inc., a wholly owned subsidiary of the Adviser, serves as the Fund’s sub-adviser.
Portfolio Managers. As of the date of this prospectus, the Portfolio Managers listed below are jointly
and primarily responsible for the day-to-day management of the Fund’s portfolio.
|
Portfolio Managers
|
Experience with this Fund
|
Primary Title with Investment Adviser or Sub-Adviser
|
|
Christopher Davis
|
Since January 2017
|
Chairman, Davis Selected Advisers, L.P.
|
|
Pierce Crosbie
|
Since December 2018
|
Vice President, Davis Selected Advisers–NY, Inc.
|
Purchase and Sale of Fund Shares
The Fund is an actively managed ETF. Individual shares of the Fund are listed on a
national securities exchange. Individual shares may only be bought and sold in the secondary market through a broker or dealer
at a market price. As the price of Fund shares is based on the market price, and because ETF shares trade at a market price
rather than at NAV, shares may trade at a price greater than NAV (a premium) or less than NAV (a discount). An investor may
incur costs attributable to the difference between the highest price a buyer is willing to pay to purchase shares of a Fund (the
bid) and the lowest price a seller is willing to accept for shares of a Fund (the ask) when buying or selling shares in the secondary
market (the bid-ask spread). The Fund will only issue or redeem shares that have been aggregated into blocks of 25,000 shares or multiples thereof (“Creation Units”) to APs who have entered into agreements with the Fund’s distributor. The Fund generally will issue or redeem Creations Units in return for a designated portfolio of securities (and an amount of cash) the Fund
specifies each day. Current information regarding the net asset value, market price, premium and/or discount, and bid-ask
spreads on a Fund can be obtained at www.davisetfs.com.
For important information about the purchase and sale of Fund shares and tax information, please see the “Buying and Selling Shares” section of the Fund’s prospectus.
Tax Information
If the Fund earns income or realizes capital gains, it intends to make distributions
that may be taxed as ordinary income, qualified dividend income or capital gains by federal, state and local authorities.
Payments to Broker-Dealers and Other Financial Intermediaries
If you purchase the Fund through a broker-dealer or other financial intermediary (such
as a bank), the Fund and its related companies may pay the intermediary for the sale of Fund shares and related services.
These payments may create a conflict of interest by influencing the broker-dealer or other intermediary and your salesperson
to recommend the Fund over another investment. Ask your salesperson or visit your financial intermediary’s website for more information.
Prospectus | Davis Fundamental ETF Trust | 18
Additional Information About Investment Objectives, Principal Strategies, and Principal Risks
This prospectus contains important information about investing in the Funds. Please
read this prospectus carefully before you make any investment decisions. Additional information regarding the Funds is available
at davisetfs.com/literature/regulatory-documents.
Shares of each Fund are listed for trading on Cboe Global Markets, Inc. The Funds'
shares trade under the trading symbols “DUSA” (Davis Select U.S. Equity ETF), “DINT” (Davis Select International ETF), “DWLD” (Davis Select Worldwide ETF) and “DFNL” (Davis Select Financial ETF).
Investment Objective
Each Fund’s investment objective is non-fundamental and may be changed by the Board of Trustees (the “Board”) of Davis Fundamental ETF Trust (the “Trust”) without shareholder approval. There is no assurance that a Fund will meet its investment objective.
Principal Investment Strategies
The principal investment strategies and risks for the Funds are described in more
detail above and below. The prospectus and statement of additional information (“SAI”) contain a number of investment strategies and risks that may be important to consider even though they are not principal investment strategies or principal risks
for the Funds. The prospectus also contains disclosure that describes Davis Advisors’ process for determining when the Funds may pursue a non-principal investment strategy.
The principal risks, but not the only risks, for each Fund are summarized in the summary
section of this Prospectus for each Fund as well as in each Fund’s Summary Prospectus. More details on some of the principal investment strategies and risks are described above and below. DUSA, DFNL, DINT and DWLD would provide Fund shareholders with at least 60 days’ prior notice before changing its name policy. The statement of additional information (“SAI”) includes a “Name Policy” section, which contains additional information.
Many foreign markets operate at times that do not coincide with the New York Stock
Exchange. As a result, the closing prices of securities that trade on foreign markets may be as much as 15 hours old by the
time a fund calculates its net asset value, and may not reflect the current market values of those securities. In particular, the
closing prices of foreign securities may not reflect their market values at a Fund’s net asset value calculation if a significant event that will affect the value of those securities has occurred since the closing prices were established on the foreign exchange or market, but before a Fund’s net asset value calculation. This situation could lead to a pricing error and dilution of shareholders’ investment in a Fund.
Principal Risks of Investing in the Funds
If you buy shares of the Funds, you may lose some or all of the money that you invest.
The investment return and principal value of an investment in the Funds will fluctuate so that an investor’s shares, when redeemed, may be worth more or less than their original cost. The likelihood of loss may be greater if you invest for a shorter
period of time. This section describes the principal risks (but not the only risks) that could cause the value of your investment
in the Funds to decline and which could prevent them from achieving their stated investment objectives.
The principal risks of investing in the Funds, listed alphabetically, include:
China Risk – Generally (DWLD and DINT only). Investments in Chinese securities may subject the Funds to risks that are specific to China. China may be subject to significant amounts of instability including,
but not limited to, economic, political, and social instability. China’s economy may differ from the U.S. economy in certain respects including, but not limited to, general development, level of government involvement, wealth distribution, and structure.
The government of China has historically demonstrated its control over almost every sector of the Chinese economy
through state ownership and/or administrative regulation. As an example, the Chinese government has taken certain
actions that have influenced prices of goods, encouraged companies to invest in certain industries, has induced mergers,
and may take such actions or similar actions now or in the future. In addition, the Chinese government has taken actions which
could materially impact the business operations of certain industries which could impact underlying holdings. U.S. and
Chinese regulators have, and may in the future, impact the ability of Chinese companies to gain access to U.S. capital markets.
As of January 31, 2026, DWLD and DINT had significant exposure to shell companies
with contractual arrangements with Variable Interest Entities (“VIEs”). For purposes of raising capital offshore on exchanges outside of China, including on U.S. exchanges, many Chinese-based operating companies are structured as VIEs. In this
structure, the Chinese-based operating company is the VIE and establishes a shell company in a foreign jurisdiction, such
as the Cayman Islands. The shell company lists on a foreign exchange and enters into contractual arrangements with the VIE.
This structure allows Chinese companies in which the government restricts foreign ownership to raise capital from foreign investors.
While the shell company has no equity ownership of the VIE, these contractual arrangements permit the shell company to consolidate the VIE’s financial statements with its own for accounting purposes and provide for economic exposure
to the performance of the underlying Chinese operating company. Therefore, an investor in the listed shell company, such
as the Funds, will have exposure to the Chinese-based operating company only through contractual arrangements and has no ownership
in the Chinese-based
Prospectus | Davis Fundamental ETF Trust | 19
operating company. Furthermore, because the shell company only has specific rights
provided for in these service agreements with the VIE, its abilities to control the activities at the Chinese-based operating
company are limited and the operating company may engage in activities that negatively impact investment value.
While the VIE structure has been widely adopted, it is not formally recognized under
Chinese law and therefore there is a risk that the Chinese government could prohibit the existence of such structures or negatively impact the VIE’s contractual arrangements with the listed shell company by making them invalid. If these contracts
were found to be unenforceable under Chinese law, investors in the listed shell company, such as the Funds, may suffer
significant losses with little or no recourse available. If the Chinese government determines that the agreements establishing the
VIE structures do not comply with Chinese law and regulations, including those related to restrictions on foreign ownership,
it could subject a Chinese-based issuer to penalties, revocation of business and operating licenses, or forfeiture
of ownership interest. In addition, the listed shell company’s control over a VIE may also be jeopardized if a natural person who holds the equity interest in the VIE breaches the terms of the agreement, is subject to legal proceedings, or if any physical
instruments for authenticating documentation, such as chops and seals, are used without the Chinese-based issuer’s authorization to enter into contractual arrangements in China. Chops and seals, which are carved stamps used to sign documents,
represent a legally binding commitment by the company. Moreover, any future regulatory action may prohibit the
ability of the shell company to receive the economic benefits of the Chinese-based operating company, which may cause the
value of the Funds' investment in the listed shell company to suffer a significant loss. For example, in 2021, the Chinese
government prohibited use of the VIE structure for investment in after-school tutoring companies. There is no guarantee
that the government will not place similar restrictions on other industries.
Chinese law prohibits investments by foreign investors in certain companies in certain
industries. Certain industries that impact minors may be at a higher risk of regulatory action. The Chinese government
placed new regulations on the companies related to after-school tutoring and private educational services, one of which is
mandating that it must now be registered as a non-profit organization.
Common Stock Risk. Common stock represents ownership positions in companies. The prices of common stock
fluctuate based on changes in the financial condition of their issuers and on market and economic
conditions. Events that have a negative impact on a business probably will be reflected in a decline in the price
of its common stock. Furthermore, when the total value of the stock market declines, most common stocks, even those issued by
strong companies, likely will decline in value. Common stock is generally subordinate to an issuer’s other securities, including preferred, convertible, and debt securities.
Cybersecurity Risk. Intentional cybersecurity breaches include: (1) unauthorized access to systems, networks
or devices (such as through “hacking” activity); (2) infection from computer viruses or other malicious software code; and (3) attacks that shut down, disable, slow or otherwise disrupt operations, business processes, website access
or functionality. In addition, unintentional incidents can occur, such as the inadvertent release of confidential
information (possibly resulting in the violation of applicable privacy laws).
A cybersecurity breach could result in the loss or theft of customer data or funds,
the inability to access electronic systems (“denial of services”), loss or theft of proprietary information or corporate data, physical damage to a computer or network system, or costs associated with system repairs. Such incidents could cause the Fund, the Fund’s adviser or sub-adviser, a financial intermediary, or other service providers to incur regulatory penalties,
reputational damage, additional compliance costs or financial loss. In addition, such incidents could affect issuers in which the Fund invests, and thereby cause the Fund’s investments to lose value. Please see the SAI for additional cybersecurity risk discussion.
Depositary Receipts Risk. Securities of a foreign company may involve investing in Depositary Receipts, which
include American Depositary Receipts, European Depositary Receipts, and Global Depositary
Receipts, which are certificates evidencing ownership of shares of a foreign issuer. These certificates, which may
be sponsored or unsponsored, are issued by depositary banks and, generally, trade on an established market in the United States
or elsewhere. The underlying shares are held in trust by a custodian bank or similar financial institution in the issuer’s home country. The depositary bank may not have physical custody of the underlying securities at all times and may charge fees for
various services, including forwarding dividends, interest, and corporate actions. Depositary Receipts are alternatives to
directly purchasing the underlying foreign securities in their national markets and currencies. However, Depositary Receipts
continue to be subject to many of the risks associated with investing directly in foreign securities. These risks include foreign
exchange risk as well as the political and economic risks of the underlying issuer’s country. Depositary Receipts may trade at a discount or a premium to the underlying security and may be less liquid than the underlying securities listed on an exchange.
Emerging Market Risk (DWLD, DINT, and DFNL only). Securities of issuers in emerging and developing markets may offer special investment opportunities but present risks not found in more mature markets.
Those securities may be more difficult to sell at an acceptable price and their prices may be more volatile than securities
of issuers in more developed markets. For example, Chinese securities may be subject to increased volatility and pricing anomalies
resulting from governmental influence, a lack of publicly available information, and/or political and social instability.
Settlements of trades may be subject to greater delays so that the Funds might not receive the proceeds of a sale of a
security on a timely basis. In unusual situations, it may not be possible to repatriate sales proceeds in a timely fashion.
These investments may be very speculative.
Prospectus | Davis Fundamental ETF Trust | 20
Emerging markets might have less developed trading markets and exchanges. These countries
may have less developed legal and accounting systems and investments may be subject to greater risks of government
restrictions on withdrawing the sale proceeds of securities from the country. Companies operating in emerging markets may
not be subject to U.S. prohibitions against doing business with countries that are state sponsors of terrorism. Economies
of developing countries may be more dependent on relatively few industries that may be highly vulnerable to local and
global changes. Governments may be more unstable and present greater risks of nationalization, expropriation, or restrictions
on foreign ownership of stocks of local companies.
As of December 31, 2025, the emerging market countries were: Bahrain, Bangladesh,
Benin, Bermuda, Brazil, Burkina Faso, Chile, China, Colombia, Croatia, Czech Republic, Egypt, Estonia, Greece, Guinea-Bissau,
Hungary, Iceland, India, Indonesia, Ivory Coast, Jordan, Kazakhstan, Kenya, Korea, Kuwait, Latvia, Lithuania, Malaysia,
Mali, Mauritius, Mexico, Morocco, Niger, Oman, Pakistan, Peru, Philippines, Poland, Qatar, Romania, Saudi Arabia, Senegal,
Serbia, Slovenia, South Africa, Sri Lanka, Taiwan, Thailand, Togo, Tunisia, Turkey, United Arab Emirates, and Vietnam.
Additionally, certain countries that are not on this list may be included at Davis Advisor’s discretion.
Exposure to Industry or Sector Risk (DWLD and DINT only). Subject to the Funds' investment limitations, the Funds may have significant exposure to a particular industry or sector. Such exposure may cause
the Funds to be more impacted by risks related to and developments affecting the industry or sector and thus its net asset
value may be more volatile than a fund without such levels of exposure. For example, if the Funds have significant exposure
in a particular industry, then economic, regulatory, or other issues that negatively affect that industry may have a greater
impact on the Funds than on a fund that is more diversified. The SAI contains additional discussion of the risks of exposure
to certain industries or sectors. An industry weighting breakdown for the Funds can be found in the most recent annual or semi-annual
report.
Financial Services Risk (DUSA and DFNL only). A company is “principally engaged” in financial services if it owns financial services related assets constituting at least 50% of the total value of
its assets, or if at least 50% of its revenues are derived from its provision of financial services. The financial services sector consists
of several different industries that behave differently in different economic and market environments, including banking,
insurance, and securities brokerage houses. Companies in the financial services sector include commercial banks, industrial
banks, savings institutions, finance companies, diversified financial services companies, investment banking firms, securities
brokerage houses, investment advisory companies, leasing companies, insurance companies, and companies providing
similar services. Due to the wide variety of companies in the financial services sector, they may react in different
ways to changes in economic and market conditions.
Risks of investing in the financial services sector include: (1) systemic risk: factors
outside the control of a particular financial institution — like the failure of another, significant financial institution or material disruptions to the credit markets — may adversely affect the ability of the financial institution to operate normally or may
impair its financial condition; (2) regulatory actions: financial services companies may suffer setbacks if regulators change the
rules under which they operate; (3) changes in interest rates: unstable and/or rising interest rates may have a disproportionate
effect on companies in the financial services sector; (4) non-diversified loan portfolios: financial services companies, whose securities
a fund purchases, may themselves have concentrated portfolios, such as a high level of loans to real estate developers,
which makes them vulnerable to economic conditions that affect that industry; (5) credit: financial services companies may
have exposure to investments or agreements, which, under certain circumstances, may lead to losses, e.g., sub-prime loans; and
(6) competition: the financial services sector has become increasingly competitive.
Banking. Commercial banks (including “money center” regional and community banks), savings and loan associations, and holding companies of the foregoing are especially subject to adverse effects of volatile
interest rates, concentrations of loans in particular industries or classifications (such as real estate, energy, or sub-prime
mortgages), and significant competition. The profitability of these businesses is to a significant degree dependent on the
availability and cost of capital funds. Economic conditions in the real estate market may have a particularly strong effect
on certain banks and savings associations. Commercial banks and savings associations are subject to extensive federal and, in
many instances, state regulation. Neither such extensive regulation nor the federal insurance of deposits ensures the solvency
or profitability of companies in this industry and there is no assurance against losses in securities issued by such companies.
Insurance. Insurance companies are particularly subject to government regulation and rate setting,
potential anti-trust and tax law changes, and industry-wide pricing and competition cycles. Property and casualty
insurance companies also may be affected by weather, terrorism, long-term climate changes, and other catastrophes.
Life and health insurance companies may be affected by mortality and morbidity rates, including the effects of epidemics.
Individual insurance companies may be exposed to reserve inadequacies, problems in investment portfolios (e.g., real estate or “junk” bond holdings), and failures of reinsurance carriers.
Other Financial Services Companies. Many of the investment considerations discussed in connection with banks and insurance companies also apply to other financial services companies. These companies
are subject to extensive regulation, rapid business changes and volatile performance dependent on the availability and
cost of capital, and prevailing interest rates and significant competition. General economic conditions significantly affect these
companies. Credit and other losses resulting from the financial difficulty of borrowers or other third parties have a
potentially adverse effect on companies in this industry. Investment banking, securities brokerage, and investment advisory companies
are particularly subject to government regulation and the risks inherent in securities trading and underwriting activities.
Prospectus | Davis Fundamental ETF Trust | 21
Other Regulatory Limitations. Regulations of the Securities and Exchange Commission (“SEC”) impose limits on: (1) investments in the securities of companies that derive more than 15% of their gross
revenues from the securities or investment management business (although there are exceptions, the Fund is prohibited from investing
more than 5% of its total assets in a single company that derives more than 15% of its gross revenues from the securities
or investment management business); and (2) investments in insurance companies. The Fund, generally, is prohibited from
owning more than 10% of the outstanding voting securities of an insurance company.
Focused Portfolio Risk (DUSA and DFNL only). Funds that invest in a limited number of companies may have more risk because changes in the value of a single security may have a more significant effect,
either negative or positive, on the value of the Fund’s total portfolio.
A Fund may be classified as a “non-diversified” fund under the 1940 Act, which means that it is permitted to invest its assets in a more limited number of issuers than “diversified” investment companies. A diversified investment company may not, with respect to 75% of its total assets, invest more than 5% of its total assets in the
securities of any one issuer (other than U.S. Government securities and securities of other investment companies) and may not
own more than 10% of the outstanding voting securities of any one issuer. While a Fund may be a non-diversified investment
company, and therefore not subject to the statutory diversification requirements discussed above, the Fund may still intend
to diversify its assets to the extent necessary to qualify for tax treatment as a regulated investment company under the
Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”).
At any given point in time, a diversified fund may not meet the diversification test
outlined above due to appreciation in its portfolio holdings. In such case, the Fund is not required to sell portfolio holdings
to meet the diversification test.
The diversification standards under the Internal Revenue Code require that a fund
diversify its holdings so that, at the end of each fiscal quarter, (1) at least 50% of the market value of a fund’s assets are represented by cash, U.S. Government securities, securities of other regulated investment companies, and other securities limited with
respect to any one issuer to an amount not greater than 5% of a fund’s assets and 10% of the outstanding voting securities of such issuer, and (2) not more than 25% of the value of a fund’s assets is invested in the securities of any one issuer (other than U.S. Government securities and the securities of other regulated investment companies), or of two or more issuers which
a fund controls (i.e., owns, directly or indirectly, 20% of the voting stock) and which are determined to be engaged in the
same or similar trades or businesses or related trades or businesses.
Foreign Country Risk. Foreign companies may issue both equity and fixed income securities. A company may
be classified as either “domestic” or “foreign” depending upon which factors the Adviser considers most important for a given company. Factors that the Adviser considers in classifying a company as domestic or foreign
include: (1) whether the company is organized under the laws of the United States or a foreign country; (2) whether the company’s securities principally trade in securities markets outside of the United States; (3) the source of the majority of the company’s revenues or profits; and (4) the location of the majority of the company’s assets. The Adviser generally follows the country classification indicated by a third-party service provider but may use a different country classification if the Adviser’s analysis of the four factors provided above, or other factors that the Adviser deems relevant, indicate that a different
country classification is more appropriate. Foreign country risk can be more focused on factors concerning specific countries
or geographic areas when the Funds' holdings are more focused in these countries or geographic areas.
The Funds may invest a significant portion of their assets in securities issued by
companies operating, incorporated, or principally traded in foreign countries. Investing in foreign countries involves risks
that may cause the Funds' performance to be more volatile than it would be if the Funds invested solely in the United States.
Foreign economies may not be as strong or as diversified, foreign political systems may not be as stable and foreign financial
reporting standards may not be as rigorous as they are in the United States. In addition, foreign capital markets may not be
as well developed, so securities may be less liquid, transaction costs may be higher, and investments may be subject to more government
regulation. When the Funds invest in foreign securities, their operating expenses are likely to be higher than those
of an investment company investing exclusively in U.S. securities, since the custodial and certain other expenses associated
with foreign investments are expected to be higher.
Foreign Currency Risk. Securities issued by foreign companies in foreign markets are frequently denominated
in foreign currencies. The change in value of a foreign currency against the U.S. dollar will
result in a change in the U.S. dollar value of securities denominated in that foreign currency. For example, when the Funds hold
a security that is denominated in a foreign currency, a decline of that foreign currency against the U.S. dollar would generally
cause the value of the Funds' shares to decline. The Funds may, but generally do not, hedge their currency risk.
Foreign Market Risk (DWLD and DINT only). Because certain foreign holdings of the Funds may trade in a market that is closed when the market in which the Funds' shares are listed is open, there may be
changes between the last quote of the foreign holding from its closed foreign market and the value of such security during
the Funds' domestic trading day. This in turn could lead to differences between the market price of the Funds' shares and the
underlying value of those shares.
Headline Risk. Davis Advisors seeks to acquire companies with durable business models that can be
purchased at attractive valuations relative to what Davis Advisors believes to be the companies’ intrinsic values. Davis Advisors may make such investments when a company becomes the center of controversy after receiving adverse
media attention. The company may be involved in litigation, the company’s financial reports or corporate governance may be challenged, the company’s public
Prospectus | Davis Fundamental ETF Trust | 22
filings may disclose a weakness in internal controls, greater government regulation
may be contemplated, or other adverse events may threaten the company’s future. While Davis Advisors researches companies subject to such contingencies, it cannot be correct every time and the company’s stock may never recover or may become worthless.
Market Trading Risk. The Funds face numerous market trading risks, including disruptions to the creation
and redemption processes of the Funds, losses from trading in secondary markets, the existence of
extreme market volatility or potential lack of an active trading market for shares. These risks may result in shares trading at
a significant premium or discount to NAV. The NAV of shares will fluctuate with changes in the market value of the Funds' securities
holdings. The market prices of shares will fluctuate in accordance with changes in their NAV and supply and demand.
The Adviser cannot predict whether shares will trade below, at, or above their NAV. Price differences may be due, in
large part, to the fact that supply and demand forces for shares, at work in the secondary trading market, will be closely related,
but not identical to the same forces influencing the prices of the securities in the Funds' portfolios, trading individually
or in the aggregate at any point in time. The shareholder may sustain losses if a shareholder purchases shares at a time when
the market price is at a premium to the NAV or sells shares at a time when the market price is at a discount to the NAV. Any
of these factors, discussed above and further below, among others, may lead to shares trading at a premium or discount to
the Funds' NAV.
Absence of Prior Active Market. While the Funds' shares are expected to be listed on the Exchange, there can be no
assurance that an active trading market for shares will develop or be maintained. The Distributor
does not maintain a secondary market in shares.
Trading Issues. Trading in shares on the Exchange may be halted due to market conditions or for reasons
that, in the view of the Exchange, make trading in shares inadvisable. In addition, trading in shares on
the Exchange is subject to trading halts caused by extraordinary market volatility pursuant to the Exchange’s “circuit breaker” rules. There can be no assurance that the requirements of the Exchange necessary to maintain the listing of shares of the
Funds will continue to be met.
Trading Costs. Buying or selling the Fund shares on an Exchange involves two types of costs that
apply to all securities transactions. When buying or selling shares of the Funds through a broker, you will
likely incur a brokerage commission and other charges. In addition, you may incur the cost of the “spread,” which is the difference between what investors are willing to pay for Fund shares (the “bid” price) and the price at which they are willing to sell Fund shares (the “ask” price). There may also be regulatory and other charges that are incurred as a result of trading activity.
Because of the costs inherent in buying or selling Fund shares, frequent trading may detract significantly from investment results
and an investment in Fund shares may not be advisable for investors who anticipate regularly making small investments through
a brokerage account.
Mid- and Small-Capitalization Companies Risk. Companies with less than $10 billion in market capitalization are considered by the Adviser to be mid- or small-capitalization companies. Investing in mid- and
small-capitalization companies may be more risky than investing in large-capitalization companies. Smaller companies typically
have more limited product lines, markets, and financial resources than larger companies and their securities may trade
less frequently and in more limited volume than those of larger, more mature companies. Securities of these companies
may be subject to volatility in their prices. They may have a limited trading market, which may adversely affect the Funds' ability
to dispose of them and can reduce the price the Funds might be able to obtain for them. Other investors that own a security
issued by a mid- or small-capitalization company for whom there is limited liquidity might trade the security when the Funds
are attempting to dispose of their holdings in that security. In that case, the Funds might receive a lower price for
their holdings than otherwise might be obtained. Mid- and small-capitalization companies also may be unseasoned. These include
companies that have been in operation for less than three years, including the operations of any predecessors.
Shareholder Concentration Risk. From time to time, a relatively large percentage (over 20%) of the Funds' shares may
be held by related shareholders. A large redemption by one or more of such shareholders
may: (1) reduce the Funds' liquidity, (2) increase the Funds' transactions and transaction costs, (3) result in substantial
capital gains distributions for shareholders, and (4) increase the Funds' ongoing operating expenses, which could negatively impact
the remaining shareholders of the Funds.
Stock Market Risk. Stock markets tend to move in cycles, with periods of rising prices and periods of
falling prices, including the possibility of sharp declines. As an example, U.S. and international markets have
experienced volatility in recent months and years due to a number of economic, political, and global macro factors including
the impact of the coronavirus (COVID-19) as a global pandemic, uncertainties regarding interest rates, rising inflation, trade
tensions, and the threat of tariffs and/or retaliatory tariffs imposed by the U.S. and other countries. While COVID-19 is no
longer a global pandemic as of 2023, the recovery from COVID-19 may last for a prolonged period of time. In addition, as a
result of continuing political tensions and armed conflicts, including the war between Ukraine and Russia, the U.S. and the European
Union imposed sanctions on certain Russian individuals and companies, including certain financial institutions,
and have limited certain exports and imports to and from Russia. The war may continue to contribute to market volatility.
Further, the Israel-Hamas war may lead to overall economic uncertainty and negative impacts on the global economy and major
financial markets. These developments as well as other events could result in further market volatility and
negatively affect financial asset prices, the liquidity of certain securities, and the normal operations of securities exchanges
and other markets. Continuing market volatility as a result of recent market conditions, U.S. political developments, or
other events may have an adverse effect on the performance of the Funds.
An investment in the Funds is not a deposit of the bank and is not insured or guaranteed
by the Federal Deposit Insurance Corporation or any other government agency.
Prospectus | Davis Fundamental ETF Trust | 23
Non-Principal Investment Strategies and Risks
Davis Fundamental ETF Trust may implement investment strategies that are not principal
investment strategies if, in the Adviser’s professional judgment, the strategies are appropriate. A strategy includes any policy, practice, or technique used by the Funds to achieve their investment objectives. Whether a particular strategy, including
a strategy to invest in a particular type of security, is a principal investment strategy depends on the strategy’s anticipated importance in achieving the Funds' investment objectives and how the strategy affects the Funds' potential risks and
returns. In determining what is a principal investment strategy, the Adviser considers, among other things, the amount of the
Funds' assets expected to be committed to the strategy, the amount of the Funds' assets expected to be placed at risk by the
strategy, and the likelihood of the Funds losing some or all of those assets from implementing the strategy. Non-principal investment
strategies are generally those investments that constitute less than 5% to 10% of the Funds' assets, depending upon
their potential impact on the investment performance of the Funds.
While the Adviser expects to pursue the Funds' investment objectives by implementing
the principal investment strategies described in this prospectus, the Adviser may employ non-principal investment strategies or securities if, in Davis Advisors’ professional judgment, the securities, trading, or investment strategies are appropriate.
Factors that Davis Advisors considers in pursuing these other strategies include whether the strategy: (1) is likely to be consistent with shareholders’ reasonable expectations; (2) is likely to assist the Adviser in pursuing the Funds' investment
objectives; (3) is consistent with the Funds' investment objectives; (4) will not cause the Funds to violate any of their fundamental
or non-fundamental investment restrictions; and (5) will not materially change the Funds' risk profile from the
risk profile that results from following the principal investment strategies as described in this prospectus and further explained
in the SAI, as amended from time to time.
Repurchase Agreements. The Funds may enter into repurchase agreements. Repurchase agreements are transactions
in which the Funds purchase government securities and simultaneously commits to resell them
to the same counterparty at a future time and at a price reflecting a market rate of interest. Income from repurchase agreements
may not be exempt from state and local taxation. Repurchase agreements often offer a higher yield than investments directly
in government securities. The resale price reflects the purchase price plus an agreed-on incremental amount, which is unrelated
to the coupon rate or maturity of the purchased security. The repurchase obligation of the seller is, in effect, secured
by the underlying securities. In the event of a bankruptcy or other default of a seller of a repurchase agreement, the Funds could
experience both delays in liquidating the underlying securities and losses, including (1) possible decline in the value of the
collateral during the period, while the Funds seek to enforce their rights thereto; (2) possible loss of all or a part of the income
during this period; and (3) expenses of enforcing its rights.
The Funds will enter into repurchase agreements only when the seller agrees that the
value of the underlying securities, including accrued interest (if any), will at all times be equal to or exceed the value
of the repurchase agreement. The Funds may enter into tri-party repurchase agreements in which a third-party custodian bank
ensures the timely and accurate exchange of cash and collateral. The majority of these transactions run from day-to-day and
delivery pursuant to the resale typically occurs within one to seven days of the purchase. The Funds normally will not enter
into repurchase agreements maturing in more than seven days.
Short-Term Investments. The Funds may use short-term investments, such as treasury bills and repurchase agreements,
to maintain flexibility while evaluating long-term opportunities.
Temporary Defensive Investments. The Funds may, but are not required to, use short-term investments for temporary
defensive purposes. In the event that Davis Advisors’ Portfolio Managers anticipate a decline in the values of the companies in which the Funds invest (due to economic, political, or other factors), the Funds may
reduce their risk by investing in short-term securities until market conditions improve. While the Funds are invested in short-term
investments, they will not be pursuing their long-term growth of capital investment objective. Unlike equity securities,
these investments will not appreciate in value when the market advances and will not contribute to long-term growth of capital.
For more details concerning current investments and market outlook, please see the
Funds' most recent shareholder report.
Management and Organization
Davis Selected Advisers, L.P. (“Davis Advisors”) serves as the investment adviser for each of the Davis ETFs. Davis Advisors’ offices are located at 2949 East Elvira Road, Suite 101, Tucson, Arizona 85756. Davis
Advisors provides investment advice for the Davis ETFs, manages their business affairs and provides day-to-day administrative
services. Davis Advisors also serves as investment adviser for other mutual funds and institutional and individual clients.
Pursuant to the Investment Advisory Agreement between Davis Advisors and the Trust, each Fund pays the Adviser a monthly
fee at an annual rate of 0.55% (stated as a percentage of the average daily net assets of the Fund). For the fiscal year-ended October 31, 2025, Davis Advisors’ net management fee paid by the Funds for its services (based on average net assets) was:
DUSA, 0.55%; DFNL, 0.55%; DWLD, 0.55%; and DINT, 0.54%. A discussion regarding the basis for the approval of the Funds’ investment advisory and service agreement by the Funds’ Board of Trustees is contained in the Funds’ most recent Form N-CSR annual financial statements.
Davis Selected Advisers–NY, Inc. serves as the sub-adviser for the Davis Fundamental ETF Trust. Davis Selected Advisers–NY, Inc.’s offices are located at 620 Fifth Avenue, 3rd Floor, New York, New York 10020. Davis Selected Advisers–NY, Inc.
Prospectus | Davis Fundamental ETF Trust | 24
provides investment management and research services for the Davis Fundamental ETF
Trust and other institutional clients, and is a wholly owned subsidiary of Davis Advisors. Davis Selected Advisers–NY, Inc.’s fee is paid by Davis Advisors, not Davis Fundamental ETF Trust.
Execution of Portfolio Transactions. Davis Advisors places orders with broker-dealers for the portfolio transactions of
Davis Fundamental ETF Trust. Davis Advisors seeks to place portfolio transactions with brokers
or dealers who will execute transactions as efficiently as possible and at the most favorable net price. In placing
executions and paying brokerage commissions or dealer markups, Davis Advisors considers price, commission, timing,
competent block trading coverage, capital strength and stability, research resources, and other factors. Subject to
best price and execution, Davis Advisors may place orders for Davis ETFs' portfolio transactions with broker-dealers who have sold
shares of the Funds. However, when Davis Advisors places orders for the Funds' portfolio transactions, it does not give
any consideration to whether a broker-dealer has sold shares of the Funds. In placing orders for Davis ETFs' portfolio transactions,
the Adviser does not commit to any specific amount of business with any particular broker-dealer.
Over the last three fiscal years, the Funds paid the following brokerage commissions:
|
Fiscal Year Ended October 31,
|
2025
|
2024
|
2023
|
|
DUSA
|
|
|
|
|
Brokerage commissions paid:
|
$87,122
|
$49,002
|
$87,380
|
|
Brokerage as a percentage of average net assets:
|
0.01%
|
0.01%
|
0.03%
|
|
DINT
|
|
|
|
|
Brokerage commissions paid:
|
$142,796
|
$63,226
|
$40,006
|
|
Brokerage as a percentage of average net assets:
|
0.06%
|
0.04%
|
0.03%
|
|
DWLD
|
|
|
|
|
Brokerage commissions paid:
|
$211,750
|
$102,930
|
$42,457
|
|
Brokerage as a percentage of average net assets:
|
0.05%
|
0.03%
|
0.02%
|
|
DFNL
|
|
|
|
|
Brokerage commissions paid:
|
$9,738
|
$1,240
|
$13,032
|
|
Brokerage as a percentage of average net assets:
|
0.01%
|
0.01%
|
0.01%
|
Portfolio Managers
◼
Christopher Davis has served as a Portfolio Manager of the DUSA and DFNL since January 2017 and also
manages other equity funds advised by Davis Advisors. Mr. Davis has served as an Analyst and Portfolio
Manager for Davis Advisors since 1989.
◼
Danton Goei has served as a Portfolio Manager of DUSA and DWLD since January 2017, of DINT since
March 2018, and also manages other equity funds advised by Davis Advisors. Mr. Goei started with
Davis Advisors as a Research Analyst in 1998.
◼
Pierce Crosbie has served as a Portfolio Manager of DFNL since December 2018 and also serves as
a research analyst for other equity funds advised by Davis Advisors. Mr. Crosbie joined Davis Advisors in
2008.
Mr. Davis and Mr. Goei are jointly and primarily responsible for the day-to-day management
of the Davis Select U.S. Equity ETF portfolio. Mr. Davis and Mr. Crosbie are jointly and primarily responsible for
the day-to-day management of the Davis Select Financial ETF portfolio. Mr. Goei is primarily responsible for the day-to-day
management of the Davis Select Worldwide ETF and the Davis Select International ETF portfolios. A limited portion of each Fund’s assets may be managed by Davis Advisors’ Research Analysts, subject to review by the Fund’s Portfolio Managers.
The SAI provides additional information about the Portfolio Managers’ compensation, other accounts managed by the Portfolio Managers, and the Portfolio Managers’ investments in the Funds.
Certain Portfolio Managers may serve on the board(s) of public companies where they,
from time to time, may have access to material, non-public information (“MNPI”). Davis Advisors has instituted policies and procedures to ensure that these Portfolio Managers will not be able to utilize MNPI for their own benefit or for any
of the accounts they manage.
Administrator, Custodian, and Transfer Agent
State Street Bank and Trust Company (“State Street”) is the administrator, custodian, and transfer agent for each Fund.
Shareholder Information
Additional shareholder information, including how to buy and sell shares of the Funds,
is available, free of charge, by calling toll-free: 1-800-279-0279 or visiting our website at www.davisetfs.com.
Procedures and Shareholder Rights Are Described by Current Prospectus and Other Disclosure
Documents
Investors should look to the most recent prospectus and SAI, as amended or supplemented
from time to time, for information concerning the Funds, including information on how to purchase and redeem Fund shares
and how to contact the Funds. The most recent prospectus and SAI (including any supplements or amendments thereto) will
be on file with the Securities and
Prospectus | Davis Fundamental ETF Trust | 25
Exchange Commission as part of the Funds' registration statement. Please also see
the back cover of this prospectus for information on other ways to obtain information about the Funds.
Buying and Selling Shares
The shares of each Fund have been approved for primary listing on Cboe Global Markets,
Inc. Shares of each Fund are available for trading during the trading day. Shares can be bought and sold throughout
the trading day like shares of other publicly traded companies. The Funds do not impose any minimum investment for shares
of a Fund purchased on an exchange or otherwise in the secondary market. The Funds’ shares trade under the trading symbols “DUSA” (Davis Select U.S. Equity ETF), “DINT” (Davis Select International ETF), “DWLD” (Davis Select Worldwide ETF) and “DFNL” (Davis Select Financial ETF).
If you buy or sell shares in the secondary market, you will incur customary brokerage
commissions and other charges on your purchase and sale transactions. The commission is frequently a fixed amount and may
be a significant proportional cost for investors seeking to buy or sell small amounts of shares.
In addition, you may incur the cost of the “spread,” that is, any difference between the bid price and the ask price in the secondary market on each leg of a round trip (purchase and sale) transaction. The
spread varies over time for shares of a Fund based on its trading volume and market liquidity. In times of severe market disruption or low trading volume in a Fund’s shares, this spread can increase significantly.
It is anticipated that shares will trade in the secondary market at prices that differ
to varying degrees from the NAV of shares (see the section “How Your Shares are Valued” for more information). During periods of disruptions to creations and redemptions or the existence of extreme market volatility, the market prices of shares
are more likely to differ significantly from the shares’ NAV. Generally, the spread is lower if a Fund has high trading volume and market liquidity, and higher if a Fund has little trading volume and market liquidity (which is often the case for funds
that are newly launched or small in size). A Fund’s spread may also be impacted by the liquidity of the underlying securities it holds, particularly for newly launched or smaller funds or in instances of significant volatility of the underlying securities.
The Depository Trust Company (“DTC”) serves as securities depository for each Fund’s shares. The shares may be held only in book-entry form; stock certificates will not be issued. DTC, or its nominee, is
the record or registered owner of all outstanding shares. Beneficial ownership of shares will be shown on the records of
DTC or its participants. Beneficial owners of shares are not considered the registered holder thereof and are subject to the
same restrictions and procedures as any beneficial owner of stocks held in book-entry or “street name” form. DTC, or its nominee, is the record owner of all outstanding shares of the Funds and is recognized as the owner of all shares for all
purposes. For more information on book-entry form, see the section in the Funds’ SAI that describes it in further detail.
The Exchange is open for trading Monday through Friday and is closed on weekends and the following holidays: New Year’s Day, Martin Luther King, Jr. Day, Washington’s Birthday, Good Friday, Memorial Day, Juneteenth National Independence Day, Independence Day, Labor Day, Thanksgiving Day, and Christmas Day. Because non-U.S.
exchanges may be open on days when the Exchange is not open, the value of the securities in a Fund’s portfolio may change on days when shareholders will not be able to purchase or sell the Funds’ shares.
Shares of a Fund may be acquired or redeemed directly from a Fund only in Creation
Units or multiples thereof, as discussed in the “Creations and Redemptions” section of this prospectus. Only an AP (as defined in the “Creations and Redemptions” section below) may engage in creation or redemption transactions directly with a Fund.
Once created, shares of a Fund generally trade in the secondary market in amounts less than a Creation Unit.
Section 12(d)(1) of the 1940 Act restricts investments by investment companies in
the securities of other investment companies. Registered investment companies are permitted to invest in each Fund beyond
the limits set forth in Section 12(d)(1), subject to certain terms and conditions set forth in SEC rules or
in an SEC exemptive order issued to the Trust. In order for a registered investment company to invest in shares of a Fund
beyond the limitations of Section 12(d)(1) pursuant to the exemptive relief obtained by the Trust, the registered investment
company must enter into an agreement with the Trust.
How Your Shares Are Valued
The NAV of a Fund’s shares is determined by taking the market value of the Fund’s total assets, subtracting the Fund’s liabilities and then dividing the result (net assets) by the number of the Fund’s shares outstanding. The NAV of each Fund is determined each business day as of the close of trading (ordinarily 4:00 p.m., Eastern
time) on the New York Stock Exchange, generally, based on prices at the time of closing, provided that Fund assets or liabilities
denominated in foreign currencies are converted into U.S. dollars at the current market rates on the date of valuation as
quoted by one or more sources. A business day is generally each day that the NYSE is open for trading. Expenses and fees, including
the Management Fee, are accrued daily and taken into account for purposes of determining NAV.
The value of the securities and other assets and liabilities held by a Fund is determined
pursuant to valuation policies and procedures. Each Fund’s assets and liabilities are valued on the basis of market quotations, when readily available.
Prospectus | Davis Fundamental ETF Trust | 26
Valuation of Portfolio Securities
The Board of Trustees of the Davis Fundamental ETF Trust has delegated the determination
of fair value of securities to Davis Selected Advisers, L.P. The Adviser has implemented policies and procedures that govern
the pricing of securities for the Funds, as discussed below:
Each Fund values securities for which market quotations are readily available at current
market value. Short-term securities are valued at amortized cost. Securities listed on the NYSE and Cboe Global Markets,
Inc. (and other national exchanges) are valued at the last reported sales price on the day of valuation. Securities traded
in the OTC market and listed securities for which no sale was reported on that date are valued at the last quoted bid price. Securities
traded on foreign exchanges are valued based upon the last sales price on the principal exchange on which the security
is traded, prior to the time when the Fund’s assets are valued.
Securities, including illiquid or restricted securities, for which market quotations
are not readily available are valued at their fair value. Securities whose values have been materially affected by a significant event occurring before a Fund’s assets are valued but after the close of their respective exchanges will be fair valued. Fair
value is determined in good faith using consistently applied procedures. Fair valuation is based on subjective factors and,
as a result, the fair value price of a security may differ from the security’s market price and may not be the price at which the security may be sold. Fair valuation could result in a different NAV than an NAV determined by using market quotations. The Board
of Trustees reviews and discusses with management a summary of fair valued securities in quarterly board meetings.
In general, foreign securities are more likely to require a fair value determination
than domestic securities because circumstances may arise between the close of the market on which the securities trade
and the time when a Fund values its portfolio securities, which may affect the value of such securities. Securities denominated
in foreign currencies and traded in foreign markets will have their values converted into U.S. dollar equivalents at the
prevailing exchange rates as computed by State Street Bank and Trust Company. Fluctuation in the values of foreign currencies
in relation to the U.S. dollar may affect the net asset value of a Fund’s shares even if there has not been any change in the foreign currency prices of that Fund’s investments.
Securities of smaller companies are also generally more likely to require a fair value
determination because they may be thinly traded and less liquid than traditional securities of larger companies.
The Funds may occasionally be entitled to receive award proceeds from litigation relating
to an investment security. The Funds generally do not recognize a gain on contingencies until such payment is certain,
which in most cases is when a Fund receives payment.
To the extent that a Fund’s portfolio investments trade in markets on days when the Fund is not open for business, the Fund’s NAV may vary on those days. In addition, trading in certain portfolio investments
may not occur on days the Fund is open for business because markets or exchanges other than the NYSE may be closed. If the exchange or market on which the Fund’s underlying investments are primarily traded closes early, the NAV may be calculated
prior to its normal market calculation time. For example, the primary trading markets for a Fund may close early on the day
before certain holidays and the day after Thanksgiving.
Fixed income securities may be valued at prices supplied by a Fund’s pricing agent based on broker or dealer supplied valuations or matrix pricing, a method of valuing securities by reference to the value
of other securities with similar characteristics such as rating, interest rate, and maturity. Government bonds, corporate
bonds, asset-backed bonds, convertible securities, and high-yield or junk bonds are normally valued on the basis of prices
provided by independent pricing services. Prices provided by the pricing services may be determined without exclusive reliance
on quoted prices and may reflect appropriate factors such as institutional trading in similar groups of securities,
developments related to special securities, dividend rate, maturity, and other market data. Prices for fixed income securities
received from pricing services sometimes represent best estimates. In addition, if the prices provided by the pricing service
and independent quoted prices are unreliable, the Adviser will arrive at its own fair valuation using its fair value procedures.
Premium and Discount Information
Davis ETF’s website, which is publicly accessible at no charge, contains, on a per share basis, the prior business day’s NAV and market closing price or bid/ask price of the shares, a calculation of the premium
or discount of the market closing price or bid/ask price against such NAV, and other relevant information about premiums and
discounts.
Portfolio Holdings
A description of the Funds’ policies and procedures with respect to the disclosure of their portfolio holdings is available in the SAI.
Each business day, before the commencement of trading in Fund shares on the Exchange,
the Trust publicly disseminates each Fund’s full portfolio holdings as of the close of the previous day through its website at www.davisetfs.com.
In addition, the Funds file their complete schedule of investments with the SEC on
Form N-CSR (as of the end of the second and fourth quarters) and on Form N-PORT Part F (as of the end of the first and third quarters). The Funds’ Forms N-CSR
Prospectus | Davis Fundamental ETF Trust | 27
(Annual and Semi-Annual Reports) and N-PORT Part F are available, without charge,
upon request, by calling 1-800-279-0279, on the Funds’ website at www.davisetfs.com, and on the SEC’s website at www.sec.gov.
How the Funds Pay Earnings
There are two ways you can receive payments from a Fund:
◼
Dividends. Dividends are distributions to shareholders of net investment income and short-term
capital gains on investments.
◼
Capital Gains. Capital gains are profits received by a Fund from the sale of securities held for
the long term, which are then distributed to shareholders.
No dividend reinvestment service is provided by the Funds. Broker-dealers may make
available the DTC book-entry dividend reinvestment service for the use of beneficial owners of a Fund for reinvestment of
their dividend distributions. Beneficial owners should contact their broker to determine the availability and costs of the
service and the details of participation therein. Brokers may require beneficial owners to adhere to specific procedures and timetables.
If this service is available and exercised, dividend distributions of both income and realized gains will be automatically
reinvested in additional whole shares of the same Fund purchased in the secondary market.
Dividends and Distributions
◼
Each Fund ordinarily distributes dividends and capital gains, if any, at least annually
but a Fund may make distributions on a more frequent basis. Each Fund reserves the right to declare special distributions
if, in its reasonable discretion, such action is necessary or advisable to preserve its status as a regulated investment
company or to avoid imposition of income or excise taxes on undistributed income or realized gains.
◼
When a dividend or capital gain is distributed, the NAV per share is reduced by the
amount of the payment.
◼
Dividend payments are made through DTC participants and indirect participants to beneficial
owners, then of record, with proceeds received from a Fund. Your broker is responsible for distributing any dividends
and capital gain distributions to you.
Federal Income Taxes
The following discussion is very general. Because each shareholder’s circumstances are different and special tax rules may apply, you should consult your tax adviser about your investment in a Fund. As with
any investment, you should consider how your investment in shares of a Fund will be taxed.
You will generally have to pay federal income taxes, as well as any other state and
local taxes, on any distributions that may be received from a Fund. If you sell Fund shares, it is generally considered a taxable
event. The following table summarizes the tax status to you of certain transactions related to a Fund:
|
Transaction
|
Federal Tax Status
|
|
Sale of shares
|
Usually capital gain or loss; long term, only if shares owned more than
one year
|
|
Distributions of net capital gain
(excess of net long-term capital gain over net short-term
capital loss)
|
Long-term capital gain
|
|
Ordinary dividends
(including distributions of net short-term capital gain)
|
Ordinary income; certain dividends potentially taxable at long-term
capital gain rates
|
Distributions of net long-term capital gains (net long-term capital gains in excess
of net short-term capital losses), if any, are taxable to you as long-term capital gains, regardless of how long you have owned your
shares. Certain dividends may be treated as “qualified dividend income,” which for non-corporate shareholders is taxed at reduced rates. “Qualified dividend income” generally is income derived from dividends paid by U.S. corporations or certain foreign corporations that are either incorporated in a U.S. possession or eligible for tax benefits under certain U.S.
income tax treaties. In addition, dividends received from foreign corporations may be treated as qualified dividend income, if
the stock, with respect to which the dividends are paid, is readily tradable on an established U.S. securities market.
A portion of the dividends received from a Fund (but none of its capital gain distributions) may qualify for the dividends-received
deduction for corporate shareholders.
You may want to avoid buying shares when a Fund is about to declare a dividend or
distribution because it will be taxable to you even though it may effectively be a return of a portion of your investment. Similarly,
shareholders that are investing through a taxable account should consider the embedded gains or losses of a Fund.
For example, a new shareholder could be subject to taxes on a distribution received from a Fund that was earned when not a
shareholder. It is important to note that investors are only taxed on their own economic income over the life of the investment.
The embedded gains or losses for each Fund are disclosed in the most recent annual and semi-annual report.
The Funds’ dividends and other distributions are generally treated as received by shareholders when they are paid. However, if any dividend or distribution is declared by a Fund in October, November or December
of any calendar year and payable to
Prospectus | Davis Fundamental ETF Trust | 28
shareholders of record on a specified date in such a month, but is actually paid during
the following January, such dividend or distribution will be treated as received by each shareholder on December 31 of the
year in which it was declared.
To the extent a Fund invests in foreign securities, it may be subject to foreign withholding
taxes with respect to dividends or interest the Fund received from sources in foreign countries. If more than 50% of
the total assets of a Fund consists of foreign securities, such Fund will be eligible to elect to treat some of those taxes as a
distribution to shareholders, which would allow shareholders to offset some of their U.S. federal income tax. A Fund (or its administrative
agent) will notify you if it makes such an election and provide you with the information necessary to reflect foreign
taxes paid on your income tax return.
Tax Status of Share Transactions. Each sale of Fund shares or redemption of Creation Units will generally be a taxable
event. Any capital gain or loss realized upon a sale of Fund shares is generally treated
as a long-term gain or loss if the shares have been held for more than twelve months. Any capital gain or loss realized upon a sale
of Fund shares held for twelve months or less is generally treated as short-term gain or loss. Any capital loss on the sale
of Fund shares held for six months or less is treated as long-term capital loss to the extent distributions of net capital gain
were paid (or treated as paid) with respect to such Fund shares. Any loss realized on a sale will be disallowed to the extent Fund shares
of the applicable Fund are acquired, including through reinvestment of dividends, within a 61-day period beginning 30 days
before and ending 30 days after the sale of Fund shares. For tax purposes, an exchange of Fund shares of one ETF for Fund
shares of a different ETF is the same as a sale.
A person who exchanges securities for Creation Units, generally, will recognize gain
or loss from the exchange. The gain or loss will be equal to the difference between the market value of the Creation Units
at the time of the exchange and the exchanger’s aggregate basis in the securities surrendered plus any cash paid for the Creation Units. A person who exchanges Creation Units for securities will generally recognize a gain or loss equal to the difference between the exchanger’s basis in the Creation Units and the aggregate market value of the securities and the amount of
cash received.
Non-U.S. Investors. If you are a nonresident alien individual or a foreign corporation, trust or estate, (1) a Fund’s ordinary income dividends will generally be subject to a 30% U.S. withholding tax, unless a
lower treaty rate applies or unless such income is effectively connected with a U.S. trade or business; but (2) gains from
the sale or other disposition of shares of a Fund, generally, are not subject to U.S. taxation, unless you are a nonresident alien
individual who is physically present in the U.S. for 183 days or more per year. A Fund may, under certain circumstances, report
all or a portion of a dividend as an “interest-related dividend” or a “short-term capital gain dividend,” which would generally be exempt from this 30% U.S. withholding tax, provided certain other requirements are met. Different tax consequences
may result if you are a foreign shareholder engaged in a trade or business within the United States or if you are
a foreign shareholder entitled to claim the benefits of a tax treaty.
The foregoing discussion summarizes some of the consequences under current federal
tax law of an investment in a Fund. It is not a substitute for personal tax advice. Consult your personal tax advisor about
the potential tax consequences of an investment in a Fund under all applicable tax laws.
Creations and Redemptions
Prior to trading in the secondary market, shares of a Fund are “created” at NAV by market makers, large investors and institutions only in block-size Creation Units of 25,000 shares or multiples thereof. Each “creator” or AP has entered into an agreement with the Distributor, Foreside Fund Services, LLC.
A creation transaction, which is subject to acceptance by the Distributor, generally,
takes place when an AP deposits into a Fund a designated portfolio of securities (including any portion of such securities
for which cash may be substituted) and a specified amount of cash, approximating the holdings of that Fund, in exchange for
a specified number of Creation Units. To the extent practicable, the composition of such portfolio generally corresponds pro
rata to the holdings of a Fund. However, creation and redemption baskets may differ and the Trust reserves the right to permit
or require the substitution of cash or other securities, also known as a custom order.
Similarly, shares can be redeemed only in Creation Units, generally, for a designated
portfolio of securities (including any portion of such securities for which cash may be substituted) held by a Fund and a
specified amount of cash. Except when aggregated in Creation Units, shares are not redeemable by a Fund.
The prices at which creations and redemptions occur are based on the next calculation
of NAV after a creation or redemption order is received in an acceptable form under the AP Agreement.
Only an AP may create or redeem Creation Units directly with a Fund.
In the event of a system failure or other interruption, including disruptions at market
makers or APs, orders to purchase or redeem Creation Units either may not be executed according to a Fund’s instructions or may not be executed at all, or a Fund may not be able to place or change orders.
To the extent a Fund engages in in-kind transactions, it intends to comply with the
U.S. federal securities laws in accepting securities for deposit and satisfying redemptions with redemption securities by, among
other means, assuring that any securities accepted for deposit and any securities used to satisfy redemption requests
will be sold in transactions that would be
Prospectus | Davis Fundamental ETF Trust | 29
exempt from registration under the Securities Act of 1933, as amended (the “1933 Act”). Further, an AP that is not a “qualified institutional buyer,” as such term is defined under Rule 144A of the 1933 Act, will not be able to receive restricted securities eligible for resale under Rule 144A.
Creations and redemptions must be made through a firm that is either a member of the
Continuous Net Settlement System of the National Securities Clearing Corporation or a DTC participant that has executed
an agreement with the Distributor with respect to creations and redemptions of Creation Unit aggregations. Information about
the procedures regarding creation and redemption of Creation Units (including the cut-off times for receipt of creation
and redemption orders) is included in the Funds’ SAI.
Because new shares may be created and issued on an ongoing basis, a “distribution,” as such term is used in the 1933 Act, may be occurring at any point during the life of a Fund. Broker-dealers and other persons
are cautioned that some activities on their part may, depending on the circumstances, result in their being deemed participants
in a distribution in a manner that could render them statutory underwriters subject to the prospectus delivery and liability
provisions of the 1933 Act. Any determination of whether one is an underwriter must take into account all the relevant
facts and circumstances of each particular case.
Broker-dealers should also note that dealers who are not “underwriters,” but are participating in a distribution (as contrasted to ordinary secondary transactions), and thus dealing with shares that are part of an “unsold allotment” within the meaning of Section 4(a)(3)(C) of the 1933 Act, would be unable to take advantage of the prospectus
delivery exemption provided by Section 4(a)(3) of the 1933 Act. For delivery of prospectuses to exchange members,
the prospectus delivery mechanism of Rule 153 under the 1933 Act is available only with respect to transactions on a national
securities exchange.
Costs Associated with Creations and Redemptions
APs are charged standard creation and redemption transaction fees to offset transfer
and other transaction costs associated with the issuance and redemption of Creation Units. The standard creation and redemption
transaction fees are set forth in the table below. The standard creation transaction fee is charged to the AP on the day
such AP creates a Creation Unit and is the same regardless of the number of Creation Units purchased by the AP on the applicable
business day. Similarly, the standard redemption transaction fee is charged to the AP on the day such AP redeems a Creation
Unit and is the same regardless of the number of Creation Units redeemed by the AP on the applicable business day. Creations
and redemptions for cash (when cash creations and redemptions, in whole or in part, are available or specified) are also
subject to an additional charge as a percentage of NAV (up to the maximum amounts shown in the table below). This charge
is intended to compensate for brokerage, tax, foreign exchange, execution, price movement and other costs and expenses
related to cash transactions. Investors who use the services of a broker or other financial intermediary to acquire
or dispose of Fund shares may pay fees for such services. The following table shows, as of January 31, 2025, the approximate
value of one Creation Unit, standard fees and maximum additional charges for creations and redemptions, as described above:
|
|
Approximate Value of
a Creation Unit
|
Creation
Unit Size
|
Standard Creation
and Redemption Fee:
|
Maximum Additional
Charge for Creations
|
Maximum Additional
Charge for Redemptions
|
|
DUSA
|
$1,310,322
|
25,000
|
$150
|
3.0%
|
3.0%
|
|
DINT
|
$731,682
|
25,000
|
$300
|
3.0%
|
3.0%
|
|
DWLD
|
$1,168,231
|
25,000
|
$300
|
3.0%
|
3.0%
|
|
DFNL
|
$1,197,390
|
25,000
|
$300
|
3.0%
|
3.0%
|
Fees Paid to Dealers and Other Financial Intermediaries
Davis Advisors and its affiliates may make payments to broker-dealers, banks, registered
investment advisers or other intermediaries (“Qualifying Dealers”) related to marketing and educational activities (e.g., presentations, training programs, conferences or their making shares of the Funds available to their customers, including
in certain investment programs). These fees are paid by Davis Advisors or affiliates from their own resources. Payments of
this type are sometimes referred to as revenue-sharing payments. A financial intermediary may make decisions about which
investment options it recommends or makes available and the level of services provided to its customers based on the payments
it is eligible to receive. Therefore, such payments to an intermediary create conflicts of interest between the intermediary
and its customers and may cause the intermediary to recommend a Fund over another investment. More information regarding
these payments can be found in the Funds’ SAI. Investors should consult their financial intermediaries regarding the details of payments they may receive in connection with the sale of Fund shares.
In 2025, the Adviser was charged additional fees by the Qualifying dealer(s) listed
below. The Adviser paid these fees from its own resources. These Qualifying Dealers may provide Davis ETFs enhanced sales and
marketing support, and financial advisers employed by the Qualifying Dealers may recommend Davis ETFs rather than other
funds. Qualifying Dealers may be added or deleted at any time.
Morgan Stanley Smith Barney LLC; Pershing LLC; and Wells Fargo Advisors LLC.
In addition, the Adviser may, from time-to-time, pay additional cash compensation
or other promotional incentives to authorized dealers or agents who sell shares of Davis ETFs. In some instances, such
cash compensation or other incentives may be offered only to certain dealers or agents who employ registered representatives
who have sold or may sell significant amounts of shares of Davis ETFs during specified periods of time.
Prospectus | Davis Fundamental ETF Trust | 30
Although Davis ETFs may use brokers who sell shares of the Funds to execute portfolio
transactions, the Funds do not consider the sale of Fund shares as a factor when selecting brokers to execute portfolio
transactions.
Due Diligence Meetings. The Adviser routinely sponsors due diligence meetings for registered representatives,
during which they receive updates on various Davis ETFs and are afforded the opportunity to speak with the Funds’ Portfolio Managers. Invitation to these meetings is not conditioned on selling a specific number of shares.
Those who have shown an interest in Davis ETFs, however, are more likely to be considered. To the extent permitted by their firm’s policies and procedures, registered representatives’ expenses in attending these meetings may be covered by the Adviser.
Seminars and Educational Meetings. The Adviser may defray certain expenses of Qualifying Dealers incurred in connection
with seminars and other educational efforts subject to the Adviser’s policies and procedures governing payments for such seminars. The Adviser may share expenses with Qualifying Dealers for costs incurred
in conducting training and educational meetings about various aspects of the Funds for the employees of Qualifying Dealers.
In addition, the Adviser may share expenses with Qualifying Dealers for costs incurred in hosting client seminars at
which the Fund is discussed.
Other Compensation. The Adviser and affiliates may, from its own resources and not from a Fund’s, pay additional fees to the extent not prohibited by state or federal laws, the Securities and Exchange Commission (“SEC”), or any self-regulatory agency, such as the Financial Industry Regulatory Authority (FINRA).
Frequent Purchases and Redemptions of Fund Shares
The Board has evaluated the risks of frequent purchases and redemptions of Fund shares (“market timing”) by a Fund’s shareholders. The Board has adopted a policy of not monitoring for market timing that
appears to attempt to take advantage of a potential arbitrage opportunity presented by a lag between a change in the value of a Fund’s portfolio securities after the close of the primary markets for a Fund’s portfolio securities and the reflection of that change in its NAV, because it sells and redeems its shares directly through transactions that are in-kind and/or for cash.
The Board noted that shares can only be purchased and redeemed directly from a Fund
in Creation Units by APs and that the vast majority of trading in shares occurs on the secondary market. Because secondary
market trades do not involve a Fund directly, it is unlikely those trades would cause many of the harmful effects of market
timing, including dilution, disruption of portfolio management, increases in a Fund’s trading costs and the realization of capital gains. With respect to trades directly with a Fund, to the extent affected in-kind, those trades do not cause any of the
harmful effects (as previously noted) that may result from frequent cash trades. To the extent that a Fund allows or requires trades
to be effected in whole or in part in cash, the Board noted that those trades could result in dilution to a Fund and increased
transaction costs, which could negatively impact its ability to achieve its investment objective. However, the Board noted that
direct trading by APs is critical to ensuring that shares trade at or close to NAV. Each Fund also employs fair valuation pricing
to minimize potential dilution from market timing. Each Fund imposes transaction fees on in-kind purchases and redemptions of
shares to cover the custodial and other costs incurred by a Fund in affecting in-kind trades; these fees increase if an investor
substitutes cash, in part or in whole, for securities, reflecting the fact that a Fund’s trading costs increase in those circumstances. Given this structure, the Board determined that it is not necessary to adopt policies and procedures to detect and
deter market timing of shares. The Board has not adopted a policy of monitoring for other frequent trading activity because shares
of a Fund are listed for trading on a national securities exchange.
Financial Highlights
The financial highlights table is intended to help you understand the Funds' financial
performance for the past 5 years ended October 31, 2025. Certain information reflects financial results for a single
Fund share. The total returns in the table represent the rate that an investor would have earned (or lost) on an investment
in the Funds (assuming reinvestment of all dividends and distributions). This information has been derived
from information audited by KPMG LLP, whose report, along with the Funds' financial statements, are included in
the Annual Financial Statements and Other Information, which is available upon request.
Prospectus | Davis Fundamental ETF Trust | 31
DAVIS FUNDAMENTAL ETF TRUST
The following financial information represents selected data for each share of capital
stock outstanding throughout each period:
|
|
|
|
Income (Loss) from Investment Operations
|
||
|
|
|
Net Asset Value,
Beginning of
Period
|
Net Investment
Incomea
|
Net Realized
and
Unrealized Gains
(Losses)
|
Total from
Investment
Operations
|
|
Davis Select U.S. Equity ETF:
|
|||||
|
|
Year ended October 31, 2025
|
$41.54
|
$0.49
|
$6.30
|
$6.79
|
|
|
Year ended October 31, 2024
|
$31.12
|
$0.33
|
$11.28
|
$11.61
|
|
|
Year ended October 31, 2023
|
$26.46
|
$0.39
|
$4.60
|
$4.99
|
|
|
Year ended October 31, 2022
|
$35.03
|
$0.31
|
$(8.50)
|
$(8.19)
|
|
|
Year ended October 31, 2021
|
$25.29
|
$0.17
|
$9.72
|
$9.89
|
|
Davis Select Financial ETF:
|
|||||
|
|
Year ended October 31, 2025
|
$37.62
|
$0.82
|
$7.01
|
$7.83
|
|
|
Year ended October 31, 2024
|
$26.12
|
$0.70
|
$11.51
|
$12.21
|
|
|
Year ended October 31, 2023
|
$27.29
|
$0.61
|
$(0.87)
|
$(0.26)
|
|
|
Year ended October 31, 2022
|
$32.03
|
$0.51
|
$(4.56)
|
$(4.05)
|
|
|
Year ended October 31, 2021
|
$19.31
|
$0.39
|
$12.68
|
$13.07
|
|
Davis Select Worldwide ETF:
|
|||||
|
|
Year ended October 31, 2025
|
$37.81
|
$0.48
|
$7.45
|
$7.93
|
|
|
Year ended October 31, 2024
|
$26.67
|
$0.50
|
$11.00
|
$11.50
|
|
|
Year ended October 31, 2023
|
$22.03
|
$0.36
|
$4.47
|
$4.83
|
|
|
Year ended October 31, 2022
|
$31.04
|
$0.28
|
$(8.99)
|
$(8.71)
|
|
|
Year ended October 31, 2021
|
$26.32
|
$0.17
|
$4.63
|
$4.80
|
|
Davis Select International ETF:
|
|||||
|
|
Year ended October 31, 2025
|
$23.85
|
$0.48
|
$4.60
|
$5.08
|
|
|
Year ended October 31, 2024
|
$16.92
|
$0.48
|
$6.77
|
$7.25
|
|
|
Year ended October 31, 2023
|
$14.44
|
$0.32
|
$2.23
|
$2.55
|
|
|
Year ended October 31, 2022
|
$20.53
|
$0.26
|
$(5.93)
|
$(5.67)
|
|
|
Year ended October 31, 2021
|
$20.62
|
$0.24
|
$(0.27)
|
$(0.03)
|
a
Per share calculations were based on average shares outstanding for the period.
b
Net asset value total return is calculated assuming an initial investment made at
the net asset value at the beginning of the period, with all dividends and distributions reinvested in additional shares on the reinvestment date, and redemption
at the net asset value calculated on the last business day of the fiscal period. Market price total return is calculated assuming an initial investment
made at the market price at the beginning of the period, with all dividends and distributions reinvested in additional shares on the reinvestment date,
and sale at the market price calculated on the last business day of the fiscal period. Market price is determined by trading that occurs on the Cboe Global
Markets, Inc., and may be greater or less than net asset value, depending on the 4:00 P.M. EST official closing price of the Fund. Until December
2020, market price was determined using the midpoint of the bid-ask prices.
Prospectus | Davis Fundamental ETF Trust | 32
Financial Highlights - (Continued)
|
Dividends and Distributions
|
|
|
|
|
|
Ratios to Average Net Assets
|
|
||||
|
Dividends
from Net
Investment
Income
|
Distributions
from Realized
Gains
|
Total
Distributions
|
Net Asset
Value, End
of Period
|
Total
Return Net
Asset
Valueb
|
Market
Price, End
of Period
|
Total
Return
Market
Priceb
|
Net Assets,
End of Period
(in thousands)
|
Gross
Expense
Ratio
|
Net Expense
Ratioc
|
Net
Investment
Income
Ratio
|
Portfolio
Turnoverd
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$(0.32)
|
$(0.04)
|
$(0.36)
|
$47.97
|
16.45%
|
$48.09
|
16.44%
|
$859,856
|
0.59%
|
0.59%
|
1.10%
|
8%
|
|
$(0.38)
|
$(0.81)
|
$(1.19)
|
$41.54
|
37.99%
|
$41.65
|
38.40%
|
$542,126
|
0.59%
|
0.59%
|
0.86%
|
9%
|
|
$(0.32)
|
$(0.01)
|
$(0.33)
|
$31.12
|
19.06%
|
$31.11
|
18.88%
|
$350,120
|
0.61%
|
0.61%
|
1.28%
|
18%
|
|
$(0.18)
|
$(0.20)
|
$(0.38)
|
$26.46
|
(23.61)%
|
$26.49
|
(23.54)%
|
$318,857
|
0.61%
|
0.61%
|
0.99%
|
12%
|
|
$(0.15)
|
$–
|
$(0.15)
|
$35.03
|
39.19%
|
$35.03
|
39.41%
|
$395,803
|
0.61%
|
0.61%
|
0.51%
|
24%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$(0.69)
|
$(0.14)
|
$(0.83)
|
$44.62
|
21.22%
|
$44.68
|
20.88%
|
$303,448
|
0.61%
|
0.61%
|
1.98%
|
1%
|
|
$(0.62)
|
$(0.09)
|
$(0.71)
|
$37.62
|
47.35%
|
$37.76
|
48.33%
|
$223,820
|
0.63%
|
0.63%
|
2.12%
|
1%
|
|
$(0.59)
|
$(0.32)
|
$(0.91)
|
$26.12
|
(1.02)%
|
$26.05
|
(1.39)%
|
$154,129
|
0.64%
|
0.64%
|
2.23%
|
7%
|
|
$(0.40)
|
$(0.29)
|
$(0.69)
|
$27.29
|
(12.89)%
|
$27.32
|
(12.91)%
|
$173,281
|
0.63%
|
0.63%
|
1.77%
|
7%
|
|
$(0.35)
|
$–
|
$(0.35)
|
$32.03
|
68.35%
|
$32.07
|
68.71%
|
$229,013
|
0.62%
|
0.62%
|
1.40%
|
10%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$(0.53)
|
$–
|
$(0.53)
|
$45.21
|
21.31%
|
$45.31
|
21.34%
|
$482,654
|
0.62%
|
0.62%
|
1.19%
|
19%
|
|
$(0.36)
|
$–
|
$(0.36)
|
$37.81
|
43.54%
|
$37.88
|
43.89%
|
$342,187
|
0.63%
|
0.63%
|
1.55%
|
34%
|
|
$(0.19)
|
$–
|
$(0.19)
|
$26.67
|
21.94%
|
$26.65
|
21.72%
|
$241,332
|
0.63%
|
0.63%
|
1.34%
|
15%
|
|
$(0.30)
|
$–
|
$(0.30)
|
$22.03
|
(28.27)%
|
$22.06
|
(28.03)%
|
$207,118
|
0.63%
|
0.63%
|
1.06%
|
17%
|
|
$(0.08)
|
$–
|
$(0.08)
|
$31.04
|
18.22%
|
$30.97
|
18.00%
|
$384,858
|
0.62%
|
0.62%
|
0.53%
|
32%
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
$(0.51)
|
$–
|
$(0.51)
|
$28.42
|
21.89%
|
$28.43
|
21.81%
|
$261,433
|
0.66%
|
0.65%
|
1.95%
|
18%
|
|
$(0.32)
|
$–
|
$(0.32)
|
$23.85
|
43.44%
|
$23.88
|
43.13%
|
$205,131
|
0.66%
|
0.62%
|
2.42%
|
26%
|
|
$(0.07)
|
$–
|
$(0.07)
|
$16.92
|
17.60%
|
$16.98
|
18.11%
|
$144,696
|
0.66%
|
0.66%
|
1.75%
|
13%
|
|
$(0.42)
|
$–
|
$(0.42)
|
$14.44
|
(28.12)%
|
$14.43
|
(28.00)%
|
$116,999
|
0.66%
|
0.66%
|
1.45%
|
14%
|
|
$(0.06)
|
$–
|
$(0.06)
|
$20.53
|
(0.16)%
|
$20.48
|
(0.41)%
|
$258,709
|
0.64%
|
0.64%
|
1.05%
|
11%
|
c
The ratios in this column reflect the impact, if any, of certain reimbursements and/or
waivers from the Adviser.
d
The lesser of purchases or sales of portfolio securities for a period, divided by
the average of the fair value of portfolio securities owned during the period. Securities with a maturity or expiration date at the time of acquisition of
one year or less or securities received or delivered from in-kind purchases or redemptions are excluded from the calculation.
Prospectus | Davis Fundamental ETF Trust | 33
Investment Company Act File No. 811-23181
2949 East Elvira Road, Suite 101
Tucson, AZ 85756
1-800-279-0279
www.davisetfs.com
Tucson, AZ 85756
1-800-279-0279
www.davisetfs.com
Obtaining Additional Information
Additional information about the Funds' investments is available in the Funds' annual and semi-annual reports to shareholders and in Form N-CSR. In the Funds' annual report, you will find a discussion of the market conditions and investment strategies that significantly affected the Funds' performance during their last fiscal year. The SAI provides more detailed information about the Funds and their management and operations. In Form N-CSR, you will find the Funds' annual and semi-annual financial statements.
The Funds' SAI and annual report have been filed with the Securities and Exchange Commission, are incorporated into this prospectus by reference, and are legally a part of this prospectus.
The Funds' SAI, annual and semi-annual reports to shareholders, and other information such as Fund financial statements are available, without charge, upon request:
By Telephone: Call the Funds toll-free at 1-800-279-0279, Monday through Friday, from 9 a.m. to 6 p.m. Eastern time. You may also call this number for account inquiries.
By Mail: Write to Davis Fundamental ETF Trust, c/o Davis Selected Advisers, L.P., 2949 E. Elvira Rd., Ste. 101, Tucson, AZ 85756
On the Internet: davisetfs.com/literature/regulatory-documents
By email: [email protected]
From the SEC: Reports and other information about the Funds are also available on the EDGAR database on the SEC website (www.sec.gov). Additional copies of the registration statement can be obtained, for a duplicating fee, by sending an electronic request to [email protected].
Davis Select U.S. Equity ETF | DUSA
Davis Select International ETF | DINT
Davis Select Worldwide ETF | DWLD
Davis Select Financial ETF | DFNL
Davis Select International ETF | DINT
Davis Select Worldwide ETF | DWLD
Davis Select Financial ETF | DFNL
March 1, 2026
STATEMENT OF ADDITIONAL INFORMATION
Portfolios of Davis Fundamental ETF Trust
Principal U.S. Listing Exchange: Cboe Global Markets, Inc. This statement of additional information is not a prospectus and should be read in conjunction with the Funds' prospectus dated March 1, 2026. This statement of additional information incorporates the prospectus by reference. A copy of the Funds' prospectus may be obtained, without charge, by calling Investor Services at 1-800-279-0279 or by visiting our website, www.davisetfs.com/literature/regulatory-documents. The Funds' most recent annual report and semi-annual report to shareholders, and other information such as Fund financial statements, are separate documents that are available, without charge, upon request.
Principal U.S. Listing Exchange: Cboe Global Markets, Inc. This statement of additional information is not a prospectus and should be read in conjunction with the Funds' prospectus dated March 1, 2026. This statement of additional information incorporates the prospectus by reference. A copy of the Funds' prospectus may be obtained, without charge, by calling Investor Services at 1-800-279-0279 or by visiting our website, www.davisetfs.com/literature/regulatory-documents. The Funds' most recent annual report and semi-annual report to shareholders, and other information such as Fund financial statements, are separate documents that are available, without charge, upon request.
Contents
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3
|
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3
|
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3
|
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4
|
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4
|
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14
|
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18
|
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18
|
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20
|
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22
|
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22
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22
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Statement of Additional Information | Davis ETFs | 2
Section I:
Investment Objectives, Strategies, Risks, and Restrictions
Investment Objectives, Strategies, Risks, and Restrictions
This statement of additional information (the “SAI”) supplements and should be read in conjunction with the prospectus of Davis Select U.S. Equity ETF, Davis Select International ETF, Davis Select Worldwide
ETF, and Davis Select Financial ETF (each a “Fund” and jointly the “Funds”).
The Adviser and Sub-Adviser. The Funds are managed by Davis Selected Advisers, L.P. (the “Adviser”) and Davis Selected Advisers–NY, Inc. (the “Sub-Adviser”).
General Information
Each Fund is a series of Davis Fundamental ETF Trust (the “Trust”), an open-end management investment company organized as a Delaware business trust on March 18, 2016. Each series of the Trust represents
shares of beneficial interest in a separate portfolio of securities and other assets, with its own objective and policies. Davis
Select International ETF and Davis Select Worldwide ETF are each a diversified fund within the meaning of the Investment Company
Act of 1940, as amended (the “1940 Act”). The Davis Select U.S. Equity ETF and Davis Select Financial ETF are classified as non-diversified funds under the 1940 Act.
Each Fund issues and redeems shares at its net asset value per share (“NAV”) only in large block aggregations of a specified number of shares (“Creation Units”). Currently, Creation Units generally consist of 25,000 shares, though this may change from time to time. Creation Units are not expected to consist of less than 25,000
shares. As a practical matter, only institutions or large investors purchase or redeem Creation Units. Shares of the Funds are not
redeemable securities, except when aggregated in Creation Units.
The Funds generally issue and redeem shares either in exchange for (1) a basket of
securities included in its portfolio (“Deposit Securities”) together with the deposit of a specified cash payment (“Cash Component”); or (2) a cash payment equal in value to the Deposit Securities (“Deposit Cash”) together with the Cash Component. In accordance with Rule 6c-11 of the 1940 Act, each Fund may utilize baskets that are not representative of its entire portfolio. This would be considered a “custom basket” and additional information regarding baskets is included in the section titled “Purchase and Redemption of Creation Units.” The primary consideration accepted by each Fund (i.e., Deposit Securities or Deposit Cash) is set forth under “Purchase and Redemption of Creation Units” later in this SAI. The Trust reserves the right to permit or require the substitution of a “cash in lieu” amount to be added to the Cash Component to replace any Deposit Security and reserves the right to permit or require the substitution of Deposit Securities in lieu of Deposit
Cash (subject to applicable legal requirements). The shares have been approved for listing and secondary trading on
a national securities exchange (the “Exchange”). The shares will trade on the Exchange at market prices. These prices may differ from the shares’ NAV.
Shares may be issued in advance of receipt of Deposit Securities subject to various
conditions, including a requirement to maintain on deposit with the Trust cash at least equal to a specified percentage of
the value of the missing Deposit Securities, as set forth in the Participant Agreement (as defined herein). The Trust may impose
a transaction fee for each creation or redemption. In all cases, such fees will be limited in accordance with the requirements
of the U.S. Securities and Exchange Commission (the “SEC”) applicable to management investment companies offering redeemable securities. In addition to the fixed creation or redemption transaction fee, an additional transaction fee of up
to three times the fixed creation or redemption transaction fee and/or an additional variable charge may apply.
Each Fund intends to qualify each year for treatment as a regulated investment company (a “RIC”) under Subchapter M of the Internal Revenue Code of 1986, as amended (the “Code”), so that it will not be subject to federal income tax on income and gains that are timely distributed to Fund shareholders. Each Fund will invest its
assets, and otherwise conduct its operations, in a manner that is intended to satisfy the qualifying income, diversification and
distribution requirements necessary to establish and maintain eligibility for such treatment.
Certain matters under the 1940 Act, which must be submitted to a vote of the holders
of the outstanding voting securities of a series, shall not be deemed to have been effectively acted upon unless approved by
the holders of a majority of the outstanding voting shares, as defined under the 1940 Act, of each series affected by such matter.
Continuous Offering
The method by which Creation Units of shares are created and traded may raise certain
issues under applicable securities laws. Because new Creation Units of shares are issued and sold by the Trust on an ongoing basis, at any point a “distribution,” as such term is used in the Securities Act of 1933 (the “Securities Act”), may occur. Broker-dealers and other persons are cautioned that some activities on their part may, depending on the circumstances,
result in their being deemed participants in a distribution in a manner which could render them statutory underwriters and subject
them to the prospectus delivery and liability provisions of the Securities Act. For example, a broker-dealer firm or its
client may be deemed a statutory underwriter if it takes Creation Units after placing an order with Foreside Fund Services, LLC (the “Distributor”), breaks them down into constituent shares, and sells such shares directly to customers, or if it chooses
to couple the creation of a supply of new shares with an active selling effort involving solicitation of secondary market demand for
shares. A determination of whether one is an underwriter for purposes of the Securities Act must take into account all the facts
and circumstances pertaining to the
Statement of Additional Information | Davis ETFs | 3
activities of the broker-dealer or its client in the particular case, and the examples
mentioned above should not be considered a complete description of all the activities that could lead to a categorization as
an underwriter.
Broker-dealer firms should also note that dealers who are not “underwriters,” but are effecting transactions in shares, whether or not participating in the distribution of shares, are generally required to deliver
a prospectus. This is because the prospectus delivery exemption in Section 4(3) of the Securities Act is not available in respect
of such transactions as a result of Section 24(d) of the 1940 Act. Firms that incur a prospectus-delivery obligation,
with respect to shares of a Fund, are reminded that under Securities Act Rule 153, a prospectus-delivery obligation under Section
5(b)(2) of the Securities Act owed to an exchange member in connection with a sale on the Exchange is satisfied by the fact that the Funds’ prospectus is available at the Exchange upon request. The prospectus-delivery mechanism provided in Rule 153
is only available with respect to transactions on an exchange.
Investment Objectives
The investment objectives, principal investment strategies, and the main risks of
investing in the Funds are described in the Funds' prospectus. There is no assurance that the Funds will achieve their investment
objectives. An investment in the Funds may not be appropriate for all investors and short-term investing is discouraged.
The Funds' investment objectives are not fundamental policies and may be changed by the Board of Trustees without a vote of
shareholders. The Funds' prospectus would be amended prior to any change in investment objective and shareholders would be provided at least 30 days’ notice before the change in investment objective was implemented.
Non-Principal Investment Strategies and Risks
The Adviser may implement investment strategies which are not principal investment
strategies if, in its professional judgment, the strategies are appropriate. A strategy includes any policy, practice,
or technique used by the Funds to achieve their investment objectives. Whether a particular strategy, including a strategy to
invest in a particular type of security, is a principal investment strategy depends on the strategy’s anticipated importance in achieving the Funds' investment objectives, and how the strategy affects the Funds' potential risks and returns. In determining
what is a principal investment strategy, the Adviser considers, among other things, the amount of the Funds' assets expected to
be committed to the strategy, the amount of the Funds' assets expected to be placed at risk by the strategy, and the likelihood
of the Funds losing some or all of those assets from implementing the strategy. Non-principal investment strategies are generally
those investments which constitute less than 5% to 10% of a Fund’s assets depending upon their potential impact upon the investment performance of the Funds.
While the Adviser expects to pursue the Funds' investment objectives by implementing
the principal investment strategies described in the Funds' prospectus, the Funds may employ non-principal investment
strategies or securities if, in Davis Advisors’ professional judgment, the securities, trading, or investment strategies are appropriate. Factors that Davis Advisors considers in pursuing these other strategies include whether the strategy: (1) is likely to be consistent with shareholders’ reasonable expectations; (2) is likely to assist the Adviser in pursuing the Funds'
investment objectives; (3) is consistent with the Funds' investment objectives; (4) will not cause the Funds to violate any of their
fundamental or non-fundamental investment restrictions; and (5) will not materially change the Funds' risk profile
from the risk profile that results from following the principal investment strategies as described in the Funds' prospectus
and further explained in this SAI, as amended from time to time.
The composition of the Funds' portfolios and the strategies that the Adviser may use
to try to achieve the Funds' investment objectives may vary depending on market conditions and available investment opportunities.
The Funds are not required to use any of the investment strategies described below in pursuing their investment objectives.
The Funds may use some of the investment strategies rarely or not at all. Whether the Funds use a given investment
strategy at a given time depends on the professional judgment of the Adviser.
The principal investment strategies and risks for the Funds are described in the Funds'
prospectus. An investment strategy that is a principal investment strategy for one Fund may be a non-principal investment
strategy for one of the other Funds, which, therefore, may only invest a limited portion of its assets in the non-principal investment
strategy, as described above. A number of investment strategies and risks, which are not principal investment strategies
or principal risks for the Funds (and, therefore, are not included in the Funds' prospectus), are described below.
Equity Strategies and Risks
Emphasizing Investments in Selected Market Sectors (DUSA, DWLD, and DINT only). The Funds may invest up to 25% of their net assets in the securities of issuers conducting their principal business
activities in the same market sector. Significant investments in selected market sectors render a portfolio particularly vulnerable
to the risks of its target sectors. Such exposure may cause the Funds to be more impacted by risks relating to and developments affecting
that market sector. For purposes of measuring concentration in a market sector, the Funds generally classify companies at the “industry group” or “industry” level. However, further analysis may lead the Adviser to classify companies at the
sub-industry level. See the section of this SAI on Investment Restrictions for further details.
Consumer Discretionary Sector Risk. Companies engaged in the design, production, or distribution of products or services
for the consumer discretionary sector (e.g., retailing and consumer services) are
subject to the risk that their products or services may become obsolete quickly. The success of these companies can depend heavily
on disposable household income and consumer spending. During periods of an expanding economy, the consumer discretionary
sector may outperform the
Statement of Additional Information | Davis ETFs | 4
consumer staples sector, but may underperform when economic conditions worsen. Moreover,
the consumer discretionary sector can be significantly affected by several factors including, without limitation,
the performance of domestic and international economies, exchange rates, changing consumer preferences, demographics,
marketing campaigns, cyclical revenue generation, consumer confidence, commodity price volatility, labor relations,
interest rates, import and export controls, intense competition, technological developments, and government regulation.
Broadline Retail Risk. Retailers, especially those that operate via the internet or direct marketing (e.g.,
online consumer services, online retail, travel) are subject to fluctuating consumer demand. Unlike
traditional brick and mortar retailers, online marketplaces and retailers must assume shipping costs or pass such costs to consumers.
Consumer access to price information for the same or similar products may cause companies that operate in the online marketplace,
retail, and travel segments to reduce profit margins in order to compete. Due to the nature of their business models,
companies that operate in the online marketplace, retail, and travel segments may also be subject to heightened cybersecurity
risk including the risk of theft or damage to vital hardware, software, and information systems. The loss or public dissemination
of sensitive customer information or other proprietary data may negatively affect the financial performance
of such companies to a greater extent than traditional brick and mortar retailers. As a result of such companies being web-based
and the fact that they process, store, and transmit large amounts of data, including personal information, for their customers,
failure to prevent or mitigate data loss or other security breaches, including breaches of vendors’ technology and systems, could expose companies that operate via the internet or direct marketing retail to a risk of loss or misuse of such information,
adversely affect their operating results, result in litigation or potential liability, and otherwise harm their businesses.
China Risk – Generally. Investment in Chinese securities may subject the Fund to risks that are specific
to China. China may be subject to significant amounts of instability, including, but not limited to, economic, political, and social instability. China’s economy may differ from the U.S. economy in certain respects, including, but not limited
to, general development, level of government involvement, wealth distribution, and structure. The government of China
has historically demonstrated its control over almost every sector of the Chinese economy through state ownership and/or administrative
regulation. As an example, the Chinese government has taken certain actions that influence prices of goods and encouraged
companies to invest in and has induced mergers in certain industries, and may take such actions or similar actions
now or in the future. In addition, the Chinese government has taken actions which could materially impact the business operations
of certain industries, which could impact underlying holdings. U.S. and Chinese regulators have, and may in the
future, impact the ability of Chinese companies to gain access to U.S. capital markets.
As of January 31, 2026, Davis Select International ETF and Davis Select Worldwide
ETF had significant exposure to shell companies with contractual arrangements with variable interest entities, as defined
below. For purposes of raising capital offshore on exchanges outside of China, including on U.S. exchanges, many Chinese-based
operating companies are structured as Variable Interest Entities (“VIEs”). In this structure, the Chinese-based operating company establishes the VIE and establishes a shell company in a foreign jurisdiction, such as the Cayman Islands.
The shell company lists on a foreign exchange and enters into contractual arrangements with the VIE. This structure allows
Chinese companies in which the government restricts foreign ownership to raise capital from foreign investors. While
the shell company has no equity ownership of the VIE, these contractual arrangements permit the shell company to consolidate the VIE’s financial statements with its own for accounting purposes and provide for economic exposure to the performance
of the underlying Chinese operating company. Therefore, an investor in the listed shell company, such as the
Fund, will have exposure to the Chinese-based operating company only through contractual arrangements and has no ownership in the
Chinese-based operating company. Furthermore, because the shell company only has specific rights provided
for in these service agreements with the VIE, its abilities to control the activities at the Chinese-based operating company
are limited and the operating company may engage in activities that negatively impact investment value.
While the VIE structure has been widely adopted, it is not formally recognized under
Chinese law and therefore there is a risk that the Chinese government could prohibit the existence of such structures or negatively impact the VIE’s contractual arrangements with the listed shell company by making them invalid. If these contracts
were found to be unenforceable under Chinese law, investors in the listed shell company, such as the Fund, may suffer significant
losses with little or no recourse available. If the Chinese government determines that the agreements establishing the
VIE structures do not comply with Chinese law and regulations, including those related to restrictions on foreign ownership,
it could subject a Chinese-based issuer to penalties, revocation of business and operating licenses, or forfeiture
of ownership interest. In addition, the listed shell company’s control over a VIE may also be jeopardized if a natural person who holds the equity interest in the VIE breaches the terms of the agreement, is subject to legal proceedings or if any physical
instruments for authenticating documentation, such as chops and seals, are used without the Chinese-based issuer’s authorization to enter into contractual arrangements in China.
Chops and seals, which are carved stamps used to sign documents, represent a legally
binding commitment by the company. Moreover, any future regulatory action may prohibit the ability of the shell company
to receive the economic benefits of the Chinese-based operating company, which may cause the value of the Fund’s investment in the listed shell company to suffer a significant loss. For example, in 2021, the Chinese government prohibited use of the
VIE structure for investment in after-school tutoring companies. There is no guarantee that the government will not place similar
restrictions on other industries.
Statement of Additional Information | Davis ETFs | 5
Chinese law prohibits investments by foreign investors in certain companies in certain
industries. Certain industries that impact minors may be at a higher risk of regulatory action. The Chinese government
placed new regulations on the companies related to after-school tutoring and private educational services, one of which is
mandating that it must now be registered as a nonprofit organization.
Industrials Sector Risk. The Industrials Sector includes manufacturers and distributors of capital goods such
as aerospace and defense, building projects, electrical components and equipment, construction machinery,
and companies that offer construction and engineering services. This sector also includes providers of commercial
and professional services including office services and supplies, security and alarm services, human resources/employment
services, and research and consulting services. Included in the industrials sector are also companies that provide transportation
services including air freight and logistics, airlines, railroads, and transportation infrastructure companies. A company
in this sector is subject to the risk that the securities of such issuer will underperform the market as a whole due to legislative
or regulatory changes, adverse market conditions, and/or increased competition affecting the industrials sector. The prices
of the securities of companies operating in the industrials sector may fluctuate due to the level and volatility of commodity
prices, the exchange value of the dollar, import controls, worldwide competition, liability for environmental damage, depletion of
resources, and mandated expenditures for safety and pollution control devices.
Information Technology Sector Risk. The Information Technology Sector includes companies that offer software and information technology services and manufacturers and distributors of technology hardware
and semiconductors. A company in this sector is subject to the risk that the securities of such issuer will underperform
the market as a whole due to legislative or regulatory changes, adverse market conditions, and/or increased competition affecting
the information technology sector. The prices of the securities of companies operating in the information technology
sector are closely tied to market competition, increased sensitivity to short product cycles and aggressive pricing,
and problems with bringing products to market.
Passive Foreign Investment Companies. Some securities of companies domiciled outside the U.S. in which the Funds may invest may be considered passive foreign investment companies (“PFICs”) under U.S. tax laws. PFICs are foreign corporations which generate primarily passive income. For federal tax purposes, a corporation is
deemed a PFIC if 75% or more of the foreign corporation’s gross income for its tax year is passive income or, in general, if 50% or more of its assets are assets that produce or are held to produce passive income. Passive income is further defined as
any income to be considered foreign personal holding company income within the subpart F provisions defined by Section
954 of the Internal Revenue Code.
Investing in PFICs involves the risks associated with investing in foreign securities,
as described above. There is also the risk that the Funds may not realize that a foreign corporation they invest in is a PFIC
for federal tax purposes. Federal tax laws impose severe tax penalties for failure to properly report investment income from
PFICs. The Funds make efforts to ensure compliance with federal tax reporting of these investments, however, there can be
no guarantee that the Funds' efforts will always be successful.
Unsponsored Depositary Receipts. The Funds may invest in both sponsored and unsponsored arrangements. In a sponsored
arrangement, the foreign issuer assumes the obligation to pay some or all of the depositary’s transaction fees, whereas, in an unsponsored arrangement, the foreign issuer assumes no obligations and the depositary’s transaction fees are paid by the holders. Foreign issuers in respect of whose securities unsponsored depositary receipts
have been issued are not necessarily obligated to disclose material information in the markets in which the unsponsored
depositary receipts are traded and, therefore, such information may not be reflected in the prices of such securities
in those markets. Shareholder benefits, voting rights, and other attached rights may not be extended to the holders of unsponsored
depositary receipts.
Investments in Other Investment Companies. The Funds can invest in securities issued by other investment companies, which can include open-end funds, closed-end funds, or exchange-traded funds (“ETFs” which are typically open-ended funds or unit investment trusts listed on a stock exchange). In some instances, an ETF or closed-end
fund may trade at market prices that are higher or lower than the NAV. The Funds may do so as a way of gaining exposure
to securities represented by the investment company’s portfolio at times when the Funds may not be able to buy those securities directly. As shareholders of an investment company, the Funds would be subject to their ratable share of that investment company’s expenses, including its advisory and administration expenses. At the same time, the Funds would bear their
own management fees and expenses. To the extent that the management fees paid to an investment company are for the same
or similar services as the management fees paid by the Funds, there would be a layering of fees that would increase expenses
and decrease returns. The Funds do not intend to invest in other investment companies unless the Portfolio Manager(s) believe
that the potential benefits of the investment justify the expenses. The Funds' investments in the securities of other
investment companies are subject to the limits that apply to those kinds of investments under the Investment Company Act of 1940, as revised (“1940 Act”).
Initial Public Offerings. An initial public offering (“IPO”) is the initial public offering of securities of a particular company. IPOs in which the Funds invest can have a dramatic impact on the Funds' performance
and assumptions about future performance based on that impact may not be warranted. Investing in IPOs involves
risks. Many, but not all, of the companies issuing IPOs are small, unseasoned companies. Many are companies that have only been
in operation for short periods of time. Small company securities, including IPOs, are subject to greater volatility in their
prices than are securities issued by more established companies. If the Funds do not intend to make a long-term investment in
an IPO (it is sometimes possible to immediately sell an IPO at a profit) the Adviser may not perform the same detailed
research on the company that it does for core holdings.
Statement of Additional Information | Davis ETFs | 6
Rights and Warrants. Rights and warrants are forms of equity securities. Warrants, basically, are options
to purchase equity securities at specific prices valid for a specific period of time. Their prices do
not necessarily move parallel to the prices of the underlying securities. Rights are similar to warrants, but normally have shorter maturities
and are distributed directly by issuers to their shareholders. Rights and warrants have no voting rights, receive
no dividends, and have no rights with respect to the assets of the issuer.
Other Forms of Equity Securities. In addition to common stock, the Funds may invest in other forms of equity securities
including preferred stocks and securities with equity conversion or purchase rights.
The prices of equity securities fluctuate based on changes in the financial condition of their issuers and on market and economic
conditions. Events that have a negative impact on a business probably will be reflected in a decline in the price
of its equity securities. Furthermore, when the total value of the stock market declines, most equity securities, even those issued
by strong companies, likely will decline in value.
Inflation Risk. Also called purchasing power risk, is the chance that the cash flows from an investment won’t be worth as much in the future because of changes in purchasing power due to inflation.
Real Estate Companies, Including REITs. Real estate securities are issued by companies that have at least 50% of the value
of their assets, gross income or net profits attributable to ownership, financing,
construction, management, or sale of real estate or to products or services that are related to real estate or the real estate
industry. The Funds do not invest directly in real estate. Real estate companies include: real estate investment trusts (“REITs”) or other securitized real estate investments, brokers, developers, lenders, and companies with substantial real estate holdings
such as paper, lumber, hotel, and entertainment companies. REITs pool investors’ funds for investment primarily in income-producing real estate or real estate-related loans or interests. A REIT is not taxed on income distributed to shareholders if
it complies with various requirements relating to its organization, ownership, assets, and income, and with the requirement
that it distribute to its shareholders at least 90% of its taxable income (other than net capital gains) each taxable year.
REITs generally can be classified as equity REITs, mortgage REITs, or hybrid REITs. Equity REITs invest the majority of their
assets directly in real property and derive their income primarily from rents. Equity REITs also can realize capital gains by
selling property that has appreciated in value. Mortgage REITs invest the majority of their assets in real estate mortgages and derive
their income primarily from interest payments. Hybrid REITs combine the characteristics of both equity REITs and mortgage
REITs. To the extent that the management fees paid to a REIT are for the same or similar services as the management
fees paid by the Funds, there will be a layering of fees which would increase expenses and decrease returns. Securities
issued by REITs may trade less frequently and be less liquid than common stock issued by other companies.
Real estate securities, including REITs, are subject to risks associated with the
direct ownership of real estate including: (1) declines in property values, because of changes in the economy or the surrounding
area or because a particular region has become less appealing to tenants; (2) increases in property taxes, operating expenses,
interest rates, or competition; (3) overbuilding; (4) changes in zoning laws; (5) losses from casualty or condemnation;
(6) declines in the value of real estate related to general and local economic conditions; (7) uninsured casualties or condemnation
losses; (8) fluctuations in rental income; (9) changes in neighborhood values; (10) the appeal of properties to tenants;
(11) increases in interest rates, and (12) access to the credit markets. The Funds also could be subject to such risks by reason
of direct ownership as a result of a default on a debt security it may own.
Equity REITs may be affected by changes in the value of the underlying property owned
by the trusts while mortgage REITs may be affected by the quality of credit extended. Equity and mortgage REITs are dependent
on management skill, may not be diversified, and are subject to project financing risks. REITs also are subject to:
heavy cash flow dependency, defaults by borrowers, self-liquidation, the possibility of failing to qualify for the favorable
federal income tax treatment generally available to REITs under the Internal Revenue Code, and failing to maintain exemption
from registration under the 1940 Act. Changes in interest rates also may affect the value of the debt securities in the
Funds' portfolios. By investing in REITs indirectly through the Funds, a shareholder will bear not only their proportionate
share of the expense of the Funds but also, indirectly, similar expenses of the REITs, including compensation of management. Some
real estate securities may be rated less than investment grade by rating services. Such securities may be subject to the
risks of high-yield, high-risk securities discussed below.
Preferred Stock Risk. Preferred stock is a form of equity security and is generally ranked behind an issuer’s debt securities in claims for dividends and assets of an issuer in a liquidation or bankruptcy. For this
reason, the price of a preferred stock may react more strongly than the debt securities of an issuer. Preferred stock is subject
to issuer and market risk that is applicable to equity securities in general. An adverse event may have a negative impact on a
company and could result in a decline in the price of its preferred stock. Preferred stock of smaller companies may be more vulnerable
to adverse developments than preferred stock of larger companies.
Convertible Securities. Convertible securities are a form of equity security. Generally, convertible securities
are bonds, debentures, notes, preferred stocks, warrants, and other securities that convert or
are exchangeable into shares of the underlying common stock at a stated exchange ratio. Usually, the conversion or exchange
is solely at the option of the holder. However, some convertible securities may be convertible or exchangeable at the option
of the issuer or are automatically converted or exchanged at a certain time, on the occurrence of certain events, or
have a combination of these characteristics. Usually a convertible security provides a long-term call on the issuer’s common stock and therefore tends to appreciate in value as the underlying common stock appreciates in value. A convertible security
also may be subject to redemption by the
Statement of Additional Information | Davis ETFs | 7
issuer after a certain date and under certain circumstances (including a specified
price) established on issue. If a convertible security held by the Funds is called for redemption, the Funds could be required to
tender it for redemption, convert it into the underlying common stock, or sell it.
Convertible bonds, debentures, and notes are varieties of debt securities and as such
are subject to many of the same risks including interest rate sensitivity, changes in debt rating, and credit risk. In addition,
convertible securities are often viewed by the issuer as future common stock subordinated to other debt and carry a lower rating than the issuer’s non-convertible debt obligations. Thus, convertible securities are subject to many of the same risks as
high-yield, high-risk securities. A more complete discussion of these risks is provided below in the sections titled “Bonds and Other Debt Securities” and “High-Yield, High-Risk Debt Securities.”
Due to its conversion feature, the price of a convertible security normally will vary
in some proportion to changes in the price of the underlying common stock. A convertible security will also normally provide
a higher yield than the underlying common stock (but generally lower than comparable non-convertible securities). Due to their
higher yield, convertible securities generally sell above their “conversion value,” which is the current value of the stock to be received on conversion. The difference between this conversion value and the price of convertible securities will
vary over time depending on the value of the underlying common stocks and interest rates. When the underlying common stocks
decline in value, convertible securities will tend not to decline to the same extent because the yield acts as a price support.
When the underlying common stocks rise in value, the value of convertible securities also may be expected to increase, but
generally will not increase to the same extent as the underlying common stocks.
Fixed income securities generally are considered to be interest rate sensitive. The
value of convertible securities will change in response to changes in interest rates. During periods of falling interest rates, the
value of convertible bonds generally rises. Conversely, during periods of rising interest rates, the value of such securities
generally declines. Changes by recognized rating services in their ratings of debt securities and changes in the ability of
an issuer to make payments of interest and principal also will affect the value of these investments.
Fixed Income Strategies and Risks
Bonds and Other Debt Securities. Bonds and other debt securities may be purchased by the Funds if the Adviser believes
that such investments are consistent with the Funds' investment strategies, may contribute
to the achievement of the Funds' investment objectives, and will not violate any of the Funds' investment restrictions.
The U.S. Government, corporations, and other issuers sell bonds and other debt securities to borrow money. Issuers pay investors
interest and generally must repay the amount borrowed at maturity. Some debt securities, such as zero-coupon bonds, do not
pay current interest, but are purchased at discounts from their face values. The prices of debt securities fluctuate, depending
on such factors as interest rates, credit quality, and maturity.
Bonds and other debt securities, generally, are subject to credit risk and interest
rate risk. While debt securities issued by the U.S. Treasury generally are considered free of credit risk, debt issued by agencies
and corporations all entail some level of credit risk. Investment grade debt securities have less credit risk than do high-yield,
high-risk debt securities. Credit risk is described more fully in the section titled “High-Yield, High-Risk Debt Securities.”
Bonds and other debt securities, generally, are interest rate sensitive. During periods
of falling interest rates, the values of debt securities held by the Fund generally rise. Conversely, during periods of rising interest
rates, the values of such securities generally decline. Changes by recognized rating services in their ratings of debt
securities and changes in the ability of an issuer to make payments of interest and principal also will affect the value of these
investments.
U.S. Government Securities. U.S. Government securities represent loans by investors to the U.S. Treasury Department
or a wide variety of government agencies and instrumentalities. Securities issued by most
U.S. Government entities are neither guaranteed by the U.S. Treasury nor backed by the full faith and credit of the U.S.
Government. These entities include, among others, the Federal Home Loan Banks (FHLBs), the Federal National Mortgage Association
(FNMA), and the Federal Home Loan Mortgage Corporation (FHLMC). Securities issued by the U.S. Treasury and a small
number of U.S. Government agencies, such as the Government National Mortgage Association (GNMA), are backed
by the full faith and credit of the U.S. Government. The values of U.S. Government and agency securities and U.S. Treasury
securities are subject to fluctuation.
U.S. Government securities include mortgage-related securities issued by an agency
or instrumentality of the U.S. Government. GNMA certificates are mortgage-backed securities representing part
ownership of a pool of mortgage loans. These loans issued by lenders such as mortgage bankers, commercial banks, and
savings and loan associations are either insured by the Federal Housing Administration or guaranteed by the Veterans Administration. A “pool” or group of such mortgages is assembled and, after being approved by GNMA, is offered to investors
through securities dealers. Once approved by GNMA, the timely payment of interest and principal on each mortgage is guaranteed
by GNMA and backed by the full faith and credit of the U.S. Government. GNMA certificates differ from bonds in that
principal is paid back monthly by the borrower over the term of the loan rather than returned in a lump sum at maturity.
GNMA certificates are characterized as “pass-through” securities because both interest and principal payments (including prepayments) are passed through to the holder of such certificates.
As of September 7, 2008, the Federal Housing Finance Agency (“FHFA”) was appointed as the conservator of FHLMC and FNMA for an indefinite period. In accordance with the Federal Housing Finance Regulatory
Reform Act of 2008 and the
Statement of Additional Information | Davis ETFs | 8
Federal Housing Enterprises Financial Safety and Soundness Act of 1992, as conservator,
the FHFA will control and oversee these entities until the FHFA deems them financially sound and solvent. During the conservatorship, each entity’s obligations are expected to be paid in the normal course of business. Although no express guarantee
exists for the debt or mortgage-backed securities issued by these entities, the U.S. Department of the Treasury, through
a securities lending credit facility and a senior preferred stock purchase agreement, has attempted to enhance the ability
of the entities to meet their obligations.
Pools of mortgages also are issued or guaranteed by other agencies of the U.S. Government.
The average life of pass-through pools varies with the maturities of the underlying mortgage instruments. In addition, a pool’s term may be shortened or lengthened by unscheduled or early payment, or by slower than expected prepayment
of principal and interest on the underlying mortgages. The occurrence of mortgage prepayments is affected by the level
of interest rates, general economic conditions, the location and age of the mortgage and other social and demographic
conditions. As prepayment rates of individual pools vary widely, it is not possible to accurately predict the average
life of a particular pool. A collateralized mortgage obligation (“CMO”) is a debt security issued by a corporation, trust, custodian, or by a U.S. Government agency or instrumentality that is collateralized by a portfolio or pool of mortgages, mortgage-backed
securities, U.S. Government securities, or corporate debt obligations. The issuer’s obligation to make interest and principal payments is secured by the underlying pool or portfolio of securities. CMOs are most often issued in two or more
classes (each of which is a separate security) with varying maturities and stated rates of interest. Interest and principal
payments from the underlying collateral (generally a pool of mortgages) are not necessarily passed directly through to the
holders of the CMOs. These payments typically are used to pay interest on all CMO classes and to retire successive class
maturities in a sequence. Thus, the issuance of CMO classes with varying maturities and interest rates may result in greater predictability
of maturity with one class and less predictability of maturity with another class than a direct investment in a mortgage-backed
pass-through security (such as a GNMA certificate). Classes with shorter maturities, typically, have lower volatility
and yield while those with longer maturities, typically, have higher volatility and yield. Thus, investments in CMOs
provide greater or lesser control over the investment characteristics than mortgage pass-through securities and offer more defensive
or aggressive investment alternatives.
Investments in mortgage-related U.S. Government securities, such as GNMA certificates
and CMOs, also involve other risks. The yield on a pass-through security typically is quoted based on the maturity of
the underlying instruments and the associated average life assumption. Actual prepayment experience may cause the yield to differ
from the assumed average life yield. Accelerated prepayments adversely impact yields for pass-through securities purchased
at a premium. The opposite is true for pass-through securities purchased at a discount. During periods of declining interest
rates, prepayment of mortgages underlying pass-through certificates can be expected to accelerate. When the mortgage
obligations are prepaid, the Funds reinvest the prepaid amounts in securities, the yields of which reflect interest rates
prevailing at that time. Therefore, the Funds' ability to maintain a portfolio of high-yielding, mortgage-backed securities
will be adversely affected to the extent that prepayments of mortgages must be reinvested in securities that have lower yields than
the prepaid mortgages. Moreover, prepayments of mortgages that underlie securities purchased at a premium could result
in capital losses. Investment in such securities also could subject the Funds to “maturity extension risk,” which is the possibility that rising interest rates may cause prepayments to occur at a slower than expected rate. This particular risk may effectively
change a security that was considered a short- or intermediate-term security at the time of purchase into a long-term security.
Long-term securities generally fluctuate more widely in response to changes in interest rates than short or intermediate-term
securities.
If the Funds purchase mortgage-backed securities that are “subordinated” to other interests in the same mortgage pool, the Funds, as holders of those securities, may only receive payments after the pool’s obligations to other investors have been satisfied. An unexpectedly high rate of defaults on the mortgages held by a mortgage pool may limit substantially the pool’s ability to make payments of principal or interest to the Funds as holders of such
subordinated securities, reducing the values of those securities or in some cases rendering them worthless; the risk of such defaults
is generally higher in the case of mortgage pools that include so-called “subprime” mortgages. An unexpectedly high or low rate of prepayment on a pool’s underlying mortgages may have similar effects on subordinated securities. A mortgage
pool may issue securities subject to various levels of subordination; the risk of non-payment affects securities at each
level, although the risk is greatest in the case of more highly subordinate securities.
The guarantees of the U.S. Government, its agencies, and its instrumentalities are
guarantees of the timely payment of principal and interest on the obligations purchased. The values of the shares issued
by the Funds are not guaranteed and will fluctuate with the value of the Funds' portfolios. Generally, when the level of interest
rates rise, the value of the Funds' investments in U.S. Government securities is likely to decline and, when the level
of interest rates decline, the value of the Funds' investments in U.S. Government securities is likely to rise.
The Funds may engage in portfolio trading primarily to take advantage of yield disparities.
Such trading strategies may result in minor temporary increases or decreases in the Funds' current income and in their
holdings of debt securities that sell at substantial premiums or discounts from face value. If expectations of changes in interest
rates or the price of the securities prove to be incorrect, the Funds' potential income and capital gain will be reduced
or its potential loss will be increased.
Interest Rate Sensitivity Risk. If a security pays a fixed interest rate and market rates increase, the value of
the fixed-rate security should decline. Interest rates may also have a powerful influence on the
earnings of financial institutions.
Credit Risk. Like any borrower, the issuer of a fixed income security may be unable to make timely
payments of interest and principal. If the issuer is unable to make payments in a timely fashion the value
of the security will decline and may become
Statement of Additional Information | Davis ETFs | 9
worthless. Financial institutions are often highly leveraged and may not be able to
make timely payments of interest and principal. Even U.S. Government Securities are subject to credit risk.
High-Yield, High-Risk Debt Securities. The real estate securities, convertible securities, bonds, and other debt securities
in which the Funds may invest may include high-yield, high-risk debt securities rated BB or lower by S&P Global (“S&P”) or Ba or lower by Moody’s Investors Service (“Moody’s”) or unrated securities. Securities rated BB or lower by S&P and Ba or lower by Moody’s are referred to in the financial community as “junk bonds” and may include D-rated securities of issuers in default. See Appendix A for a more detailed description of the rating system. Ratings
assigned by credit agencies do not evaluate market risks. The Adviser considers the ratings assigned by S&P or Moody’s as one of several factors in its independent credit analysis of issuers. A description of each bond quality category is set forth in Appendix A, titled “Quality Ratings of Debt Securities.” The ratings of Moody’s and S&P represent their opinions as to the quality of the securities that they undertake to rate. It should be emphasized, however, that ratings are relative,
subjective, and are not absolute standards of quality. There is no assurance that any rating will not change. The Funds may retain
a security whose rating has changed or has become unrated.
While likely to have some quality and protective characteristics, high-yield, high-risk
debt securities, whether or not convertible into common stock, usually involve increased risk as to payment of principal
and interest. Issuers of such securities may be highly leveraged and may not have available to them traditional methods of
financing. Therefore, the risks associated with acquiring the securities of such issuers generally are greater than is the case
with higher-rated securities. For example, during an economic downturn or a sustained period of rising interest rates, issuers
of high-yield securities may be more likely to experience financial stress, especially if such issuers are highly leveraged. During
such periods, such issuers may not have sufficient revenues to meet their principal and interest payment obligations. The issuer’s ability to service its debt obligations also may be adversely affected by specific issuer developments, or the issuer’s inability to meet specific projected business forecasts or the unavailability of additional financing. The risk of loss due to default
by the issuer is significantly greater for the holders of high-yield securities because such securities may be unsecured and
may be subordinated to other creditors of the issuer.
High-yield, high-risk debt securities are subject to greater price volatility than
higher-rated securities, tend to decline in price more steeply than higher-rated securities in periods of economic difficulty or accelerating
interest rates, and are subject to greater risk of non-payment in adverse economic times. There may be a thin trading
market for such securities, which may have an adverse impact on market price and the ability of the Funds to dispose of
particular issues and may cause the Funds to incur special securities’ registration responsibilities, liabilities and costs, and liquidity and valuation difficulties. Unexpected net redemptions may force the Funds to sell high-yield, high-risk debt securities
without regard to investment merit, thereby possibly reducing return rates. Such securities may be subject to redemptions or call
provisions, which, if exercised when investment rates are declining, could result in the replacement of such securities
with lower-yielding securities, resulting in a decreased return. To the extent that the Funds invest in bonds that are original issue
discount, zero-coupon, pay-in-kind or deferred interest bonds, the Funds may have taxable interest income greater than the
cash actually received on these issues. In order to avoid taxation at the Fund level, the Funds may have to sell portfolio securities
to meet distribution requirements.
The values of high-yield, high-risk debt securities tend to reflect individual corporate
developments to a greater extent than higher-rated securities, which react primarily to fluctuations in the general level
of interest rates. Lower-rated securities also tend to be more sensitive to economic and industry conditions than higher-rated securities.
Adverse publicity and investor perceptions, whether or not based on fundamental analysis regarding individual lower-rated
bonds, may result in reduced prices for such securities. If the negative factors such as these adversely impact
the value of high-yield, high-risk securities and the Funds hold such securities, the Funds' net asset values will be adversely affected.
The Funds may have difficulty disposing of certain high-yield, high-risk bonds because
there may be a thin trading market for such bonds. Because not all dealers maintain markets in all high-yield, high-risk
bonds, the Funds anticipate that such bonds could be sold only to a limited number of dealers or institutional investors. The
lack of a liquid secondary market may have an adverse impact on market price and the ability to dispose of particular issues and
also may make it more difficult to obtain accurate market quotations or valuations for purposes of valuing the Funds' assets.
Market quotations generally are available on many high-yield issues only from a limited number of dealers and may not necessarily
represent firm bid prices of such dealers or prices for actual sales. In addition, adverse publicity and investor perceptions
may decrease the values and liquidity of high-yield, high-risk bonds regardless of a fundamental analysis of the investment
merits of such bonds. To the extent that the Funds purchase illiquid or restricted bonds, it may incur special securities’ registration responsibilities, liabilities and costs, and liquidity and valuation difficulties relating to such bonds.
Bonds may be subject to redemption or call provisions. If an issuer exercises these
provisions when investment rates are declining, the Funds will be likely to replace such bonds with lower-yielding bonds,
resulting in decreased returns. Zero-coupon, pay-in-kind, and deferred interest bonds involve additional special considerations.
Zero-coupon bonds are debt obligations that do not entitle the holder to any periodic payments of interest prior
to maturity or a specified cash payment date when the securities begin paying current interest (the “cash payment date”) and therefore are issued and traded at discounts from their face amounts or par value. The market prices of zero-coupon securities
generally are more volatile than the market prices of securities that pay interest periodically and are likely to respond to changes
in interest rates to a greater degree than securities paying interest currently with similar maturities and credit quality. Pay-in-kind
bonds pay interest in the form of other securities rather than cash. Deferred interest bonds defer the payment of interest
to a later date. Zero-coupon, pay-in-kind
Statement of Additional Information | Davis ETFs | 10
or deferred interest bonds carry additional risk in that, unlike bonds that pay interest
in cash throughout the period to maturity, the Funds will realize no cash until the cash payment date unless a portion of such
securities are sold. There is no assurance of the value or the liquidity of securities received from pay-in-kind bonds. If the issuer
defaults, the Funds may obtain no return at all on its investment. To the extent that the Funds invest in bonds that are original
issue discount, zero-coupon, pay-in-kind, or deferred interest bonds, the Funds may have taxable interest income greater than
the cash actually received on these issues. In order to distribute such income to avoid taxation, the Funds may have to sell portfolio
securities to meet its distribution requirements under circumstances that could be adverse.
Federal tax legislation limits the tax advantages of issuing certain high-yield, high-risk
bonds. This could have a materially adverse effect on the market for high-yield, high-risk bonds.
Cash Management. For defensive purposes or to accommodate inflows of cash awaiting more permanent investment,
the Funds may temporarily and without limitation hold high-grade, short-term money market
instruments, cash, and cash equivalents, including repurchase agreements. The Funds may also invest in registered
investment companies which are regulated as money market funds or companies exempted from registration under Sections
3(c)(1) or 3(c)(7) of the 1940 Act that themselves primarily invest in temporary defensive investments, including U.S.
Government securities and commercial paper. To the extent that the management fees paid to other investment companies are
for the same or similar services as the management fees paid by the Funds, there will be a layering of fees that would increase
expenses and decrease returns. Investments in other investment companies are limited by the 1940 Act and the rules
thereunder.
In certain instances, the Funds may engage in repurchase agreement transactions through
the Fixed Income Clearing Corporation (“FICC”). FICC sells U.S. Government or agency securities to the Funds under agreements to repurchase these securities at a stated repurchase price including interest for the term of the agreement.
The term of the agreement will typically be overnight or over the weekend. The Funds, through FICC, receive delivery of the
underlying U.S. Government or agency securities as collateral, whose value is required to be at least equal to the repurchase
price. If FICC were to become bankrupt, the Funds may be delayed or may incur costs or possible losses of principal and income
in disposing of the collateral.
Master Limited Partnerships Risk. The Funds may invest in securities of master limited partnerships (“MLPs”). Investments in MLPs involve risks that differ from investments in common stock, including risks
related to the following: (1) a common unit holder’s limited control and limited rights to vote on matters affecting the MLP; (2) potential conflicts of interest between the MLP and the MLP’s general partner; (3) cash flow; (4) dilution; and (5) the general partner’s right to require unit holders to sell their common units at an undesirable time or price. MLP common unit holders
may not elect the general partner or its directors and have limited ability to remove an MLP’s general partner. MLPs may issue additional common units without unit holder approval which could dilute the ownership interests of investors holding MLP
common units. MLP common units, like other equity securities, can be affected by macro-economic and other factors affecting
the stock market in general, expectations of interest rates, investor sentiment towards an issuer or certain market sector, changes in a particular issuer’s financial condition, or unfavorable or unanticipated poor performance of a particular
issuer. Prices of common units of individual MLPs, like prices of other equity securities, also can be affected by fundamentals
unique to the partnership or company, including earnings power and coverage ratios. A holder of MLP common units
typically would not be shielded to the same extent that a shareholder of a corporation would be. In certain circumstances,
creditors of an MLP would have the right to seek return of capital distributed to a limited partner, which would continue
after an investor sold its investment in the MLP. The value of an MLP security may decline for reasons that directly relate to
the issuer such as management performance, financial leverage, and reduced demand for the issuer’s products or services.
Currently, MLPs do not pay U.S. federal income tax at the partnership level. A change
in current tax law, or a change in the underlying business mix of a given MLP, could result in an MLP being treated as a
corporation for U.S. federal income tax purposes, which could result in a requirement to pay federal income tax on its taxable
income and have the effect of reducing the amount of cash available for distribution by the MLP, resulting in a reduction of the value of the common unit holder’s investment. Changes in the laws, regulations, or related interpretations relating
to the Funds' investments in MLPs could increase the Funds' expenses, reduce its cash distributions, negatively impact the
value of an investment in an MLP, or otherwise impact the Funds' ability to implement its investment strategy. Due to the
heavy state and federal regulations that an MLP’s assets may be subject to, an MLP’s profitability could be adversely impacted by changes in the regulatory environment.
Generally, the securities markets may move down, sometimes rapidly and unpredictably,
based on overall economic conditions and other factors. The value of a security may decline due to general market conditions
that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes
in the outlook for corporate earnings, changes in interest or currency rates, or adverse investor sentiment generally. A security’s value also may decline because of factors that affect a particular industry or industries, such as labor shortages or
increased production costs and competitive conditions within an industry.
Derivatives. The Funds are prohibited from investing in derivatives, excluding certain currency
and interest rate hedging transactions. This restriction is not fundamental and may be changed by the Funds
without a shareholder vote. If the Funds do determine to invest in derivatives in the future, they will comply with Rule 18f-4
under the 1940 Act.
Statement of Additional Information | Davis ETFs | 11
Additional Non-Principal Investment Strategies and Risks
Settlement Risk. Settlement systems in some markets (especially those of developing countries) are
generally less well organized than those of more developed markets. There may be risks that settlement
may be delayed and that cash or securities belonging to the Funds may be at risk because of failures or defects in the systems.
In particular, market practice may require that payment be made before receipt of the security being purchased or that delivery
of a security be made before payment is received. In such a situation, a default by a broker or bank that is processing the
transaction may cause the Funds to suffer a loss.
Liquidity Risk Management. While it is not anticipated to be an issue, the Funds’ portfolios are managed with the restrictions and requirements of the Liquidity Rule’s limitations in mind. The Adviser monitors the adequacy and effectiveness of the implementation of the Liquidity Risk Managed Program (“LRMP”) on an ongoing basis. This monitoring includes a review of the Funds' liquidity risk based on a variety of factors including the Funds' (1) investment
strategies, (2) portfolio liquidity and cash flow projections during normal and reasonably foreseeable stressed conditions,
(3) shareholder redemptions, and (4) borrowing arrangements and other funding sources. The Liquidity Rule places a 15% limit on a fund’s illiquid investments and requires a fund that does not primarily hold assets that are highly liquid investments
to determine and maintain a minimum percentage of the fund’s net assets in highly liquid investments (highly liquid investment minimum or HLIM). The LRMP includes provisions and safeguards that are reasonably designed to comply with the
15% limit on illiquid investments and the Funds are currently classified as Funds that primarily hold highly liquid investments.
The LRMP includes the classification, no less than monthly, of the Funds' investments into one of four liquidity classifications
as provided for in the Liquidity Rule.
At a recent meeting of the Funds' Board of Trustees, the Adviser provided a written
report to the Board pertaining to the operation, adequacy, and effectiveness of implementation of the LRMP from April 1,
2024, through March 31, 2025. The report concluded that the LRMP is operating effectively and is reasonably designed
to assess and manage the Funds' liquidity risk. There can be no guarantee that the LRMP will achieve its objectives in the future.
Distressed Companies. The Funds may invest in or continue to hold debt or securities issued by distressed
companies which are or are about to be involved in reorganizations, financial restructurings, or bankruptcy.
A bankruptcy, merger, or other restructuring or a tender or exchange offer, proposed or pending at the time the Funds
invest in the debt or securities may not be completed on the terms or within the time frame contemplated which may result in
losses to the Funds. Debt obligations of distressed companies typically are unrated, lower-rated, in default, or close to default
and are generally more likely to become worthless than the securities of more financially stable companies.
Borrowing. The Funds may purchase additional securities so long as borrowings do not exceed
5% of its total assets. The Funds may obtain such short-term credit as may be necessary for the clearance of purchases
and sales of portfolio securities. The Funds may borrow from banks provided that, immediately after any such borrowing,
there is an asset coverage of at least 300% for all borrowings. In the event that such asset coverage at any time falls below
300%, the Funds shall, within three business days thereafter, reduce the amount of its borrowings to an extent that the
asset coverage of such borrowings shall be at least 300%. The Funds are not required to dispose of portfolio holdings immediately
if the Funds would suffer losses as a result. Borrowing money to meet redemptions or other purposes would have the effect
of temporarily leveraging the Funds' assets and potentially exposing the Funds to leveraged losses.
Lending Portfolio Securities. The Funds may lend their portfolio securities to certain types of eligible borrowers
approved by the Board of Trustees. The Funds have engaged State Street Bank and Trust Company (“State Street”) as the Funds' lending agent pursuant to a written agreement. The Funds will retain a portion of the securities’ lending income and will remit the remaining portion to State Street as compensation for its services as securities lending
agent. As securities lending agent, State Street will screen and select borrowers, monitor the availability of securities, negotiate
rebates, daily mark to market the loans, monitor and maintain cash collateral levels, process securities movements, and reinvest
cash collateral as directed by the Adviser or as specific in the lending agent agreement.
The Funds may engage in securities lending to earn additional income or to raise cash
for liquidity purposes. The Funds must receive collateral for a loan. Under current applicable regulatory requirements (which
are subject to change), on each business day, the loan collateral must be at least equal to the value of the loaned securities.
The collateral must consist of cash, bank letters of credit, securities of the U.S. Government or its agencies or instrumentalities,
or other cash equivalents in which the Funds are permitted to invest.
Lending activities are strictly limited as described in the section titled “Investment Restrictions.” Lending money or securities involves the risk that the Funds may suffer a loss if a borrower does not repay a
loan when due. To manage this risk, the Funds deal only with counterparties they believe to be creditworthy and require that the
counterparty deposit collateral with the Funds.
When they loan securities, the Funds still own the securities, receive amounts equal
to the dividends or interest on loaned securities, and are subject to gains or losses on those securities. The Funds also
receive one or more of: (1) negotiated loan fees; (2) interest on securities used as collateral; and/or (3) interest on any short-term
debt instruments purchased with such loan collateral. Either type of interest may be shared with the borrower. The Funds may also pay reasonable finder’s, custodian, and administrative fees in connection with these loans. The terms of the Funds' loans
must meet applicable tests under the Internal Revenue Code and must permit the Funds to reacquire loaned securities on five days’ notice or in time to vote on any important matter.
Statement of Additional Information | Davis ETFs | 12
For purposes of applying the limitation set forth below in the Investment Restrictions sub-section titled “Making Loans,” there are no limitations with respect to unsecured loans made by a Fund to an unaffiliated
party. However, if a Fund loans its portfolio securities, the obligation on the part of the Fund to return collateral
upon termination of the loan could be deemed to involve the issuance of a senior security within the meaning of Section 18(f) of the
1940 Act. In order to avoid violation of Section 18(f), a Fund may not make a loan of portfolio securities if, as a result,
more than one-third of its total asset value (at value computed at the time of making a loan) would be on loan.
Income from securities lending as of the most recent fiscal year end:
|
|
DUSA
|
DFNL
|
DWLD
|
DINT
|
|
Gross income from securities lending activities (including income from cash collateral
reinvestment)
|
$-
|
$-
|
$-
|
$-
|
|
Fees and/or compensation for securities lending activities and related services
|
|
|
|
|
|
Fees paid to State Street from a revenue split for their services as securities lending
agent
|
$-
|
$-
|
$-
|
$-
|
|
Fees paid for any cash collateral management services (including fees deducted from
a pooled
cash collateral reinvestment vehicle) that are not included in the revenue split paid
to State
Street
|
$-
|
$-
|
$-
|
$-
|
|
Administrative fees not included in revenue split
|
$-
|
$-
|
$-
|
$-
|
|
Indemnification fees not included in revenue split
|
$-
|
$-
|
$-
|
$-
|
|
Rebates (paid to borrowers)
|
$-
|
$-
|
$-
|
$-
|
|
Other fees not included in revenue split (specify)
|
$-
|
$-
|
$-
|
$-
|
|
Aggregate fees/compensation for securities lending activities
|
$-
|
$-
|
$-
|
$-
|
|
Net income from securities lending activities
|
$-
|
$-
|
$-
|
$-
|
Short Sales. When the Funds believe that a security is overvalued, they may sell the security
short and borrow the same security from a broker or other institution to complete the sale. If the price of
the security decreases in value, the Funds may make a profit and, conversely, if the security increases in value, the Funds will
incur a loss because they will have to replace the borrowed security by purchasing it at a higher price. There can be no assurance
that the Funds will be able to close out the short position at any particular time or at an acceptable price. Although the Funds'
gain is limited to the amount at which they sold a security short, their potential loss is not limited. A lender may request that
the borrowed securities be returned on short notice. If that occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur. This means that the Funds might be compelled, at the most disadvantageous
time, to replace borrowed securities previously sold short with purchases on the open market at prices significantly greater
than those at which the securities were sold short. Short selling also may produce higher than normal portfolio turnover and
result in increased transaction costs to the Funds. If the Funds sell a security short, they will either own an off-setting “long position” (an economically equivalent security which is owned) or establish a “Segregated Account” as described in this SAI.
The Funds may also make short sales “against-the-box,” in which they sell short securities they own. The Funds will incur transaction costs, including interest expenses, in connection with opening, maintaining,
and closing short sales against-the-box, which results in a “constructive sale,” requiring the Funds to recognize any taxable gain from the transaction.
The Funds have adopted a non-fundamental investment limitation that prevents a Fund
from selling any security short if it would cause more than 5% of its total assets, taken at market value, to be sold short.
This limitation does not apply to selling short against the box.
When-Issued and Delayed-Delivery Transactions. The Funds can invest in securities on a “when-issued” basis and can purchase or sell securities on a “delayed-delivery” basis. When-issued and delayed-delivery are terms that refer to securities whose terms and indenture are available and for which a market exists but that are
not available for immediate delivery.
When such transactions are negotiated, the price (which generally is expressed in
yield terms) is fixed at the time the commitment is made. Delivery and payment for the securities take place at a later
date (generally within 45 days of the date the offer is accepted). The securities are subject to change in value from market
fluctuations during the period until settlement. The value at delivery may be less than the purchase price. For example, changes in
interest rates before settlement will affect the value of such securities and may cause a loss to the Funds. During the period
between purchase and settlement, no payment is made by the Funds to the issuer and no interest accrues to the Funds from the investment.
The Funds may engage in when-issued transactions to secure what the Adviser considers
to be an advantageous price and yield at the time of entering into the obligation. When the Funds enter into a when-issued
or delayed-delivery transaction, they relies on the other party to complete the transaction. Its failure to do so may cause the
Funds to lose the opportunity to obtain the security at a price and yield the Adviser considers to be advantageous. When the Funds
engage in when-issued and delayed-delivery transactions, they do so for the purpose of acquiring or selling securities consistent
with their investment objectives and strategies, and not for the purpose of investment leverage. Although the Funds
will enter into delayed-delivery or when-issued purchase transactions to acquire securities, they can dispose of a commitment before
settlement. If the Funds choose to dispose of the right to acquire a when-issued security before its acquisition or to
dispose of its right to delivery or receive against a forward commitment, they may incur a gain or loss.
At the time the Funds make the commitment to purchase or sell a security on a when-issued
or delayed-delivery basis, they record the transaction on their books and reflect the value of the security purchased
in determining the Funds' net asset values.
Statement of Additional Information | Davis ETFs | 13
In a sale transaction, they record the proceeds to be received. The Funds will identify
on their books liquid securities of any type at least equal in value to the value of the Funds' purchase commitments until
the Funds pay for the investment.
When-issued and delayed-delivery transactions can be used by the Funds as defensive
techniques to hedge against anticipated changes in interest rates and prices. For instance, in periods of rising interest
rates and falling prices, the Funds might sell securities in their portfolios on a forward commitment basis to attempt to limit their
exposure to anticipated falling prices. In periods of falling interest rates and rising prices, the Funds might sell portfolio
securities and purchase the same or similar securities on a when-issued or delayed-delivery basis to obtain the benefit of currently
higher cash yields.
Cybersecurity Risk. With the increased use of technologies such as the Internet to conduct business,
the Funds have become potentially more susceptible to operational and information security risks through
breaches in cybersecurity. In general, a breach in cybersecurity can result from either a deliberate attack or an unintentional
event. Cybersecurity breaches may involve, among other things, infection by computer viruses or other malicious software
code, or unauthorized access to the Funds' digital information systems, networks, or devices through “hacking” or other means, in each case for the purpose of misappropriating assets or sensitive information (e.g., personal shareholder information),
corrupting data or causing operational disruption or failures in the physical infrastructure or operating systems
that support the Funds. Cybersecurity risks also include the risk of losses of service resulting from external attacks that
do not require unauthorized access to the Funds' systems, networks, or devices. For example, denial-of-service attacks on the Adviser’s or an affiliate’s website could effectively render the Funds' network services unavailable to their shareholders and
other intended end-users. Any such cybersecurity breaches or losses of service may cause the Funds to lose proprietary
information, suffer data corruption, or lose operational capacity, which, in turn, could cause the Funds to incur regulatory penalties,
reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. While
the Funds and their investment adviser have established plans and procedures designed to prevent or reduce the impact of
a cybersecurity attack, there is no guarantee that these plans and procedures will be successful. There are inherent limitations
in these plans and procedures given the ever changing nature of technology and cybersecurity attack tactics and there is a possibility
that certain risks have not been adequately identified or prepared for.
In addition, cybersecurity failures by or breaches of the Funds' third-party service
providers (including, but not limited to, the Funds' investment adviser, transfer agent, custodian, liquidity market maker, primary
exchange, authorized participants, and other financial intermediaries) may disrupt the business operations of the service
providers and of the Funds, potentially resulting in financial losses, the inability of the Funds' shareholders to transact
business with the Funds and of the Funds to process transactions, the inability of the Funds to calculate their net asset values,
violations of applicable privacy and other laws, rules and regulations, regulatory fines and penalties, reputational damage,
reimbursement or other compensatory costs, and/or additional compliance costs associated with implementation of any corrective
measures. The Funds and their shareholders could be negatively impacted as a result of any such cybersecurity breaches
and there can be no assurance that the Funds will not suffer losses relating to cybersecurity attacks or other informational
security breaches affecting the Funds' third-party service providers in the future, particularly as the Funds cannot control
cybersecurity plans or systems implemented by such service providers.
Securities the Funds invest in are subject to cybersecurity risks in similar ways
to the Funds. A cybersecurity risk or cybersecurity event may cause the Funds' investments in such issuers to lose value.
In extreme cases, a risk or event could cause the issuer to cease business.
Segregated Accounts. A number of the Funds' potential non-principal investment strategies may require
it to establish segregated accounts. When the Funds enter into an investment strategy that would result in a “senior security,” as that term is defined in the 1940 Act, the Funds will either: (1) own an off-setting position in
securities; or (2) set aside liquid securities in a segregated account with its custodian bank (or designated in the Funds' books and
records) in the amount prescribed. The Funds will maintain the value of such segregated accounts equal to the prescribed
amount by adding or removing additional liquid securities to account for fluctuations in the value of securities held in such
accounts. Securities held in a segregated account cannot be sold while the senior security is outstanding unless they are replaced
with qualifying securities and the value of the account is maintained.
A segregated account is not required when the Funds hold securities, options, or futures
positions whose value is expected to offset its obligations that would otherwise require a segregated account. The Funds
may also use other SEC approved methods to reduce or eliminate the leveraged aspects of senior securities.
Portfolio Transactions
The Adviser is responsible for the placement of portfolio transactions, subject to
the supervision of the Funds' Board of Trustees. Following is a summary of the Adviser’s trading policies which are described in Part 2 of its Form ADV. The Adviser is primarily a discretionary investment adviser. Accordingly, the Adviser generally
determines the securities and quantities to be bought and sold for each client’s account.
Portfolio turnover may vary from year to year, as well as within a year. High turnover
rates are likely to result in comparatively greater brokerage expenses or transaction costs. The overall reasonableness of brokerage
commissions and transaction costs is evaluated by the Adviser based upon its knowledge of available information as to the
general level of commissions and transaction costs paid by other institutional investors for comparable services.
Statement of Additional Information | Davis ETFs | 14
Each Fund also has a Brokerage Committee, which reviews the Funds’ trading as described in the section titled “Standing Committees of the Board of Trustees.”
Best Execution. The Adviser follows procedures intended to provide reasonable assurance of best execution.
However, there can be no assurance that best execution will in fact be achieved in any given transaction.
The Adviser seeks to place portfolio transactions with brokers or dealers who will execute transactions as efficiently
as possible and at the most favorable net price. In determining what constitutes best execution, the Adviser not only considers quantitative
factors (e.g., the possible transaction cost), but also whether the transaction represents the best qualitative
execution. In placing executions and paying brokerage commissions or dealer markups, the Adviser considers, among other factors,
price, commission, timing, aggregated trades, capable floor brokers or traders, competent block trading coverage, ability
to position, capital strength and stability, reliable and accurate communication and settlement processing, use of automation,
knowledge of other buyers or sellers, arbitrage skills, administrative ability, underwriting and provision of information
on the particular security or market in which the transaction is to occur, research, the range and quality of the services made
available to clients, and the payment of bona fide client expenses. To the extent that clients direct brokerage, the Adviser cannot
be responsible for achieving best execution. The Adviser may place orders for portfolio transactions with broker-dealers who have
sold shares of funds which the Adviser serves as adviser or sub-adviser. However, when the Adviser places orders for portfolio
transactions, it does not give any consideration to whether a broker-dealer has sold shares of the funds which the Adviser
serves as adviser or sub-adviser. The applicability of specific criteria will vary depending on the nature of the transaction,
the market in which it is executed and the extent to which it is possible to select from among multiple broker-dealers.
Cross Trades. When the Adviser deems it to be advantageous, the Funds may purchase or sell securities
directly from or to another client account which is managed by the Adviser. This may happen due to a variety
of circumstances, including situations when the Funds must purchase securities due to holding excess cash and,
at the same time, a different client of the Adviser must sell securities in order to increase its cash position. Cross trades
are only executed when deemed beneficial to the Funds and the other client and the Adviser has adopted written procedures to ensure
fairness to both parties.
Investment Allocations. The Adviser considers many factors when allocating securities among its clients, including
the Funds, including, but not limited to, the client’s investment style, applicable restrictions, availability of securities, available cash, anticipated liquidity, and existing holdings. The Adviser employs several Portfolio
Managers each of whom performs independent research and develops different levels of conviction concerning potential
investments. Clients managed by the Portfolio Manager performing the research may receive priority allocations of limited
investment opportunities that are in short supply, including IPOs.
Clients are not assured of participating equally or at all in any particular investment opportunity. The nature of a client’s investment style may exclude it from participating in many investment opportunities
even if the client is not strictly precluded from participation based on written investment restrictions. For example: (1) large-cap
value clients are unlikely to participate in IPOs of small-capitalization companies; (2) the Adviser may allocate short-term
trading opportunities to clients pursuing active trading strategies rather than clients pursuing long-term, buy-and-hold strategies;
(3) minimum block sizes may be optimal for liquidity which may limit the participation of smaller accounts; (4) it
is sometimes impractical for some custodians to deal with securities which are difficult to settle; and (5) private accounts and
managed money/wrap accounts generally do not participate in direct purchases of foreign securities, but may participate in
depositary receipts consisting of American Depositary Receipts (“ADRs”), European Depositary Receipts (“EDRs”), and Global Depositary Receipts (“GDRs”).
The Adviser attempts to allocate limited investment opportunities, including IPOs,
among clients in a manner that is fair and equitable when viewed over a considerable period of time and involving many allocations.
Generally, the Adviser allocates investments to clients utilizing a pro rata methodology. When the Adviser is limited
in the amount of a particular security it can purchase due to a limited supply, limited liquidity, or other reason, the Adviser
may allocate the limited investment opportunity to a subset of eligible clients.
The Adviser serves as investment adviser for a number of clients and may deal with
conflicts of interest when allocating investment opportunities among its various clients. For example: (1) the Adviser receives
different advisory fees from different clients; (2) the performance records of some clients are more public than the performance
records of other clients; and (3) the Adviser and its affiliates, owners, officers, and employees have invested substantial
amounts of their own capital in some client accounts (notably the Davis Funds, Selected Fund, Clipper Fund, and Davis ETFs),
but do not invest their own capital in every client’s account. The majority of the Adviser’s clients pursue specific investment strategies, many of which are similar. The Adviser expects that, over long periods of time, most clients pursuing similar
investment strategies should experience similar, but not identical, investment performance. Many factors affect investment
performance including but not limited to: (1) the timing of cash deposits and withdrawals to and from an account; (2) the
fact that the Adviser may not purchase or sell a given security on behalf of all clients pursuing similar strategies; (3) price
and timing differences when buying or selling securities; and (4) the clients’ own different investment restrictions. The Adviser’s trading policies are designed to minimize possible conflicts of interest in trading for its clients.
Limitations on Aggregate Investments in a Single Company. The Adviser’s policy is not to invest for the purpose of exercising control or management of other companies. In extraordinary circumstances,
the Adviser may seek to influence management. In such an event, appropriate government and regulatory filings would
be made.
Statement of Additional Information | Davis ETFs | 15
Federal and state laws, as well as company documents (sometimes referred to as “poison pills”) may limit the percentage of a company’s outstanding shares which may be purchased or owned by the Adviser’s clients. This is especially true in heavily regulated industries such as insurance, banking, and real estate investment trusts.
Unless it can obtain an exception, the Adviser will not make additional purchases of these companies for its clients if,
as a result of such purchase, shares in excess of the applicable investment limitation (for example, 9.9% of outstanding voting shares)
would be held by its clients in the aggregate.
Order Priority. The Adviser’s trading desk prioritizes incoming orders of similar purchases and sales of securities between institutional and managed money/wrap account orders. The Adviser’s trading desk typically executes orders for institutional clients, including investment companies, institutional private accounts, sub-advised
accounts, and others. Managed money/wrap account program sponsors typically execute orders for managed money/wrap accounts.
The Adviser’s trading desk attempts to coordinate the timing of orders with a trade rotation to prevent the Adviser from “bidding against itself” on orders. Generally, a block trade representing a portion of the total trade (approximately 1∕2 of an order given by the Portfolio Manager) is placed first for institutional and private
accounts. Once this trade is completed, the Adviser places orders for wrap accounts, one sponsor at a time. Sponsors of certain
model portfolios will execute trades for their clients. These model portfolio sponsors are included as a part of the wrap account
trade rotation. If the Adviser has not received a response from a model portfolio sponsor within a reasonable period of time,
the Adviser will resume through the trade rotation. If this occurs, it is possible that the model portfolio sponsor and
the Adviser will be executing similar trades for discretionary clients. The trading concludes with another block transaction for institutional
and private accounts. The trading desk follows procedures intended to provide reasonable assurance that no clients are
disadvantaged by this trade rotation and the compliance department monitors execution quality. However, there can be no assurance
that best execution will in fact be achieved in any given transaction.
Pattern Accounts. The Adviser serves as investment adviser for a number of clients which are patterned
after model portfolios or designated mutual funds managed by the Adviser. For example, a client pursuing the Adviser’s large-cap value strategy may be patterned after Davis New York Venture Fund. A client patterned after Davis New
York Venture Fund will usually have all of its trading (other than trading reflecting cash flows due to client deposits or
withdrawals) aggregated with that of Davis New York Venture Fund. In unusual circumstances, the Adviser may not purchase or sell
a given security on behalf of all clients (even clients managed in a similar style), and it may not execute a purchase of securities
or a sale of securities for all participating clients at the same time.
Orders for accounts which are not patterned after model portfolios or designated mutual
funds are generally executed in the order received by the trading desk with the following exceptions: (1) the execution
of orders for clients that have directed that particular brokers be used may be delayed until the orders which do not direct a particular
broker have been filled; (2) the execution of orders may be delayed when the client (or responsible Portfolio Manager)
requests such delay due to market conditions in the security to be purchased or sold; and (3) the execution of orders
which are to be bunched or aggregated.
Aggregated Trades. Generally, the Adviser’s equity Portfolio Managers communicate investment decisions to a centralized equity trading desk while fixed income Portfolio Managers normally place their transactions
themselves. The Adviser frequently follows the practice of aggregating orders of various institutional clients
for execution if the Adviser believes that this will result in the best net price and most favorable execution. In some instances,
aggregating trades could adversely affect a given client. However, the Adviser believes that aggregating trades generally benefits
clients because larger orders tend to have lower execution costs and the Adviser’s clients do not compete with each other trading in the market. Directed brokerage trades in a particular security are typically executed separately from, and possibly after, the Adviser’s other client trades.
In general, all of the Adviser’s clients (excluding clients who are directing brokerage and managed account/wrap programs) seeking to purchase or sell a given security at approximately the same time will,
generally, be aggregated into a single order or series of orders. When an aggregated order is filled, all participating clients receive
the price at which the order was executed. If, at a later time, the participating clients wish to purchase or sell additional
shares of the same security or if additional clients seek to purchase or sell the same security, then the Adviser will issue a new order
and the clients participating in the new order will receive the price at which the new order was executed.
In the event that an aggregated order is not entirely filled, the Adviser will allocate
the purchases or sales among participating clients in the manner it considers to be most equitable and consistent with its fiduciary
obligations to all such clients. Generally, partially-filled orders are allocated pro rata based on the initial order
submitted by each participating client.
In accordance with the various managed account/wrap programs in which the Adviser
participates, the Adviser typically directs all trading to the applicable program sponsor unless, in the Adviser’s reasonable discretion, doing so would adversely affect the client. Clients typically pay no commissions on trades executed through
program sponsors. In the event that an order to the sponsor of a managed account/wrap program is not entirely filled, the Adviser
will allocate the purchases or sales among the clients of that sponsor in the manner it considers to be most equitable and consistent
with its fiduciary obligations to all such clients. Generally, partially-filled orders are allocated among the particular sponsor’s participating clients on a random basis that is anticipated to be equitable over time. The Adviser may, if circumstances
permit, execute transactions for ETF clients through transfers-in-kind. There may be times that the Adviser is not able
to aggregate transactions because of applicable law or other considerations (such as tax or liquidity considerations) when
doing so might otherwise be advantageous.
Statement of Additional Information | Davis ETFs | 16
Trading Error Correction. In the course of managing client accounts, it is possible that trading errors will
occur from time to time. The Adviser has adopted Trading Error Correction Policies & Procedures which,
when the Adviser is at fault, seek to place a client’s account in the same position it would have been had there been no error. The Adviser retains flexibility in attempting to place a client’s account in the same position it would have been had there been no error. The Adviser attempts to treat all material errors uniformly, regardless of whether they would result in a
profit or loss to the client. For example, the Adviser may purchase securities from a client account at cost if they were acquired
due to a trading error. If more than one trading error or a series of trading errors is discovered in a client account, then
gains and losses on the erroneous trades may be netted.
Research Paid for with Commissions. The Adviser does not use client commissions (“Soft Dollars”) to pay for: (1) computer hardware or software or other electronic communications facilities; (2) publications,
both paper based or electronic, that are available to the general public; and (3) research reports that are created by parties
other than the broker-dealers providing trade execution, clearing, and/or settlement services to the Adviser’s clients. If the Adviser determines to purchase such services, it pays for them using its own resources.
The Adviser may receive research that is bundled with the trade execution, clearing,
and/or settlement services provided by a particular broker-dealer. The Adviser may take into account the products and services
as well as the execution capacity of a brokerage firm in selecting brokers. Thus, transactions may be directed to a brokerage
firm that provides: (1) important information concerning a company; (2) introductions to key company officers; (3) industry
and company conferences; and (4) other value added research services. The Adviser may have an incentive to select or
recommend a broker-dealer based on its interest in continuing to receive these value added research or services that the
Adviser believes are useful in its investment decision-making process but only when, in the Adviser’s judgment, the broker-dealer is capable of providing best execution for that transaction. If the Adviser were to direct brokerage to a firm providing these
value added services, the Adviser may receive a benefit as it may not have to pay for the services it has received.
Research or other services obtained in this manner may be used in servicing the Adviser’s other accounts, including in connection with other Adviser client accounts other than those that pay commissions
to the broker. Such products and services may disproportionately benefit other Adviser client accounts relative to the Funds
based on the amount of brokerage commissions paid by the Funds and such other Adviser client accounts. For example,
research or other services that are paid for through one client’s commissions may not be used in managing that client’s account.
The Adviser follows the concepts of Section 28(e) of the Securities Exchange Act of
1934. Subject to the criteria of Section 28(e), the Adviser may pay a broker a brokerage commission in excess of that
which another broker might have charged for effecting the same transactions, in recognition of the value of the brokerage
and research services provided by or through the broker. The Adviser’s Head Trader exercises their professional judgment to determine which brokerage firm is best suited to execute any given portfolio transaction. This includes transactions executed
through brokerage firms which provide the services listed above. The Adviser does not attempt to allocate soft dollar benefits
to client accounts proportionately to the commissions which the accounts pay to brokerage firms which provide research services.
The Adviser believes it is important to its investment decision-making to have access to independent research.
Exceptions. There are occasions when the Adviser varies the trading procedures and considerations
described above. The Adviser exercises its best judgment in determining whether clients should execute
portfolio transactions simultaneously with, prior to, or subsequent to the model portfolio or designated mutual fund that they
are patterned after. The factors that the Adviser considers in exercising its judgment include, but are not limited to, the
need for confidentiality of the purchase or sale, market liquidity of the securities in issue, the particular events or circumstances
that prompt the purchase or sale of the securities, and operational efficiencies. Even when transactions are executed on the
same day, clients may not receive the same price as the model portfolios or designated mutual funds they are patterned after.
If the transactions are not aggregated, such prices may be better or worse.
Portfolio Turnover. Because the Funds' portfolios are managed using the Davis Investment Discipline,
portfolio turnover is expected to be low. The Funds anticipate that, during normal market conditions, their
annual portfolio turnover rates will be less than 100%. However, depending upon market conditions, portfolio turnover rates
will vary. At times they could be high which could require the payment of larger amounts in brokerage commissions and possibly
more taxable distributions.
When the Adviser deems it to be appropriate, the Funds may engage in active and frequent
trading to achieve their investment objectives. Active trading may include participation in IPOs. Active trading may result
in the realization and distribution to shareholders of larger amounts of capital gains compared with a fund with less active
trading strategies which could increase shareholder tax liability. Active trading may also generate larger amounts of short-term
capital gains which are generally taxable as ordinary income when distributed to taxable shareholders. Frequent trading
also increases transaction costs which could detract from the Funds' performance.
Statement of Additional Information | Davis ETFs | 17
Portfolio Commissions
|
Fiscal Year-Ended October 31,
|
2025
|
2024
|
2023
|
|
DUSA
|
|
|
|
|
Brokerage commissions paid:
|
$87,122
|
$49,002
|
$87,380
|
|
Amount paid to brokers providing research:
|
None
|
None
|
None
|
|
Amount paid to brokers providing services:
|
None
|
None
|
None
|
|
DINT
|
|
|
|
|
Brokerage commissions paid:
|
$142,796
|
$63,226
|
$40,006
|
|
Amount paid to brokers providing research:
|
None
|
None
|
None
|
|
Amount paid to brokers providing services:
|
None
|
None
|
None
|
|
DWLD
|
|
|
|
|
Brokerage commissions paid:
|
$211,750
|
$102,930
|
$42,457
|
|
Amount paid to brokers providing research:
|
None
|
None
|
None
|
|
Amount paid to brokers providing services:
|
None
|
None
|
None
|
|
DFNL
|
|
|
|
|
Brokerage commissions paid:
|
$9,738
|
$1,240
|
$13,032
|
|
Amount paid to brokers providing research:
|
None
|
None
|
None
|
|
Amount paid to brokers providing services:
|
None
|
None
|
None
|
Investments in Certain Broker-Dealers. As of October 31, 2025, the Funds owned the following securities (excluding repurchase agreements) issued by any of its regular brokers and dealers. The Funds'
regular brokers and dealers are the ten brokers or dealers receiving the greatest amount of commissions from the Funds' portfolio
transactions during the most recent fiscal year, the ten brokers or dealers engaging in the largest amount of principal
transactions during the most recent fiscal year, and the ten brokers or dealers that sold the largest amount of Fund shares during
the most recent fiscal year. As of the most recent fiscal year-ended October 31, 2025, the Funds owned securities (excluding
repurchase agreements) issued by the following broker dealer(s):
|
Fund
|
Broker-Dealer
|
Value
|
|
DUSA
|
Wells Fargo & Co.
|
$31,463,311
|
|
DINT
|
None
|
|
|
DWLD
|
None
|
|
|
DFNL
|
JPMorgan Chase & Co.
|
$18,341,146
|
|
|
Wells Fargo & Co.
|
$15,405,170
|
|
|
Charles Schwab Corp.
|
$3,746,773
|
Investment Restrictions
The Funds follow investment strategies developed in accordance with their investment
objectives, policies and restrictions described in their prospectus and this SAI.
The Funds have adopted the fundamental investment policies set forth below which may
not be changed without shareholder approval. Where necessary, an explanation following a fundamental policy describes the Funds’ practices with respect to that policy as permitted by governing rules, regulations, and interpretations. If the governing
rules, regulations, and/or interpretations change, the Funds’ investment practices may change without a shareholder vote.
The fundamental investment restrictions set forth below may not be changed without
the approval of the lesser of: (1) 67% or more of the voting securities present at such meeting if the holders of more than
50% of the outstanding voting securities of such company are present or represented by proxy; or (2) more than 50% of the outstanding
voting securities of such company.
Except for the fundamental investment policies regarding borrowing, all percentage
restrictions apply as of the time of an investment without regard to any later fluctuations in the value of portfolio securities
or other assets. All references to the assets of a Fund are in terms of current value.
◼
Diversification (DINT and DWLD). The Funds may not make any investment that is inconsistent with their classification
as diversified investment companies under the 1940 Act.
Further Explanation of Diversification Policy. To remain classified as a diversified investment company under the 1940 Act, a Fund must conform with the following: with respect to 75% of its total assets,
a diversified investment company may not invest more than 5% of its total assets, determined at market or other fair
value at the time of purchase, in the securities of any one issuer or invest in more than 10% of the outstanding voting
securities of any one issuer, determined at the time of purchase. These limitations do not apply to investments in securities
issued or guaranteed by the U.S. Government or its agencies or instrumentalities or securities issued by investment
companies.
◼
Diversification (DUSA and DFNL). The Funds are not required to diversify their investments.
Further Explanation of Diversification Policy. The Funds are classified as non-diversified under the 1940 Act. The Funds intends to remain classified as regulated investment companies under the Internal
Revenue Code. This requires the Funds
Statement of Additional Information | Davis ETFs | 18
to conform to the following: at the end of each quarter of the taxable year, at least
50% of the value of the Funds' total assets must be represented by: cash and cash items, U.S. Government securities, securities
of other regulated investment companies, and “other securities.” For this purpose, “other securities” does not include investments in the securities of any one issuer that represent more than 5% of the value of the Funds' total assets or more than 10% of the issuer’s outstanding voting securities.
◼
Concentration (DUSA, DINT, and DWLD). The Funds may not concentrate their investments in the securities of issuers primarily engaged in any particular industry or group of industries.
Further Explanation of Concentration Policy. The Funds may not invest 25% or more of their total assets, taken at market value, in the securities of issuers primarily engaged in any particular industry (other
than securities issued or guaranteed by the U.S. Government or its agencies or instrumentalities). The Funds generally use
the Global Industry Classification Standard (“GICS”) as developed by Morgan Stanley Capital International and S&P Global to determine industry classification. GICS presents industry classification as a series of levels (i.e.,
sector, industry group, industry, and sub-industry). For purposes of measuring concentration, the Funds generally classify companies at the “industry group” or “industry” level. However, further analysis may lead the Adviser to classify companies at the sub-industry level. The Adviser will only measure concentration at the sub-industry level when it believes
that the various sub-industries in question can reasonably be expected to be impacted differently to a material extent
by future economic events. For example, in the “Insurance” industry, the Adviser believes that the sub-industries (insurance brokers, life & health insurance, multi-line insurance, property & casualty insurance, and reinsurance) can
reasonably be expected to be impacted differently to a material extent by future economic events such as natural
disasters, global politics, inflation, unemployment, technology, etc. In addition, the Adviser may reclassify a company into
an entirely different sector if it believes that the GICS classification on a specific company does not accurately describe
the company.
◼
Concentration (DFNL). The Fund concentrates its investments in the financial services industry.
Further Explanation of Concentration Policy. Financial services are a “sector” composed of a number of “industries,” examples of which are included in the following paragraph. The concentration policy
requires the Fund to invest at least 25% of its assets in securities principally engaged in the financial services group
of industries which together make up the financial services sector. Due to the non-fundamental Name Policy, under normal circumstances,
the Fund invests at least 80% of its net assets, plus any borrowing for investment purposes, in securities issued
by companies principally engaged in the financial services sector.
A company is “principally engaged” in financial services if it owns financial services related assets constituting at least 50% of the total value of the company’s assets or if at least 50% of the company’s revenues are derived from its provision of financial services. The financial services sector consists of several different
industries that behave differently in different economic and market environments, for example: banking, insurance, and securities
brokerage houses. Financial services companies include those with their principal business activity in one of
the following areas: banks, financial services, consumer finance, capital markets, insurance, and mortgage REITs.
The Fund may not invest 25% or more of its total assets, taken at market value, in
the securities of issuers primarily engaged in any particular industry (other than issuers in the financial services sector
or securities issued or guaranteed by the U.S. Government or its agencies or instrumentalities).
◼
Issuing Senior Securities (All Funds). The Funds may not issue senior securities, except as permitted under applicable law, including the 1940 Act and published SEC staff positions.
Further Explanation of Issuing Senior Securities. The Funds may not issue senior securities, except as provided by the 1940 Act and any rules, regulations, orders, or letters issued thereunder. This limitation
does not apply to selling short against the box. See the non-fundamental restriction further limiting short selling below. The 1940 Act defines a “Senior Security” as any bond, debenture, note, or similar obligation constituting a security and evidencing indebtedness.
◼
Borrowing (All Funds). The Funds may not borrow money, except to the extent permitted by applicable law
including the 1940 Act and published SEC staff positions.
Further Explanation of Borrowing Policy. The Funds may borrow from banks provided that, immediately thereafter, they have 300% asset coverage for all borrowings. The Funds may purchase additional securities
so long as borrowings do not exceed 5% of their total assets. The Funds may obtain such short-term credit as may
be necessary for the clearance of purchases and sales of portfolio securities. In the event that market fluctuations
cause borrowing to exceed the limits stated above, the Adviser would act to remedy the situation as promptly as possible, normally
within three business days. The Adviser is not required to dispose of portfolio holdings immediately if the Funds
would suffer losses as a result.
◼
Underwriting (All Funds). The Funds may not underwrite securities of other issuers except to the extent permitted
by applicable law, including the 1940 Act and published SEC staff positions.
Further Explanation of Underwriting Policy. The Funds may not underwrite securities of other issuers, except insofar as the Funds may be deemed to be underwriters in connection with the disposition of their
portfolio securities.
◼
Investments in Commodities and Real Estate (All Funds). The Funds may not purchase or sell commodities or real estate, except to the extent permitted by applicable law, including the 1940 Act and published
SEC staff positions.
Statement of Additional Information | Davis ETFs | 19
Further Explanation of Policy Restricting Investments in Commodities and Real Estate.
The Funds may purchase or sell financial futures contracts, options on financial futures contracts, currency contracts,
and options on currency contracts as described in its prospectus and SAI. The Funds may not purchase or sell real estate,
except that the Funds may invest in securities that are directly or indirectly secured by real estate or issued by issuers
that invest in real estate.
◼
Making Loans (All Funds). The Funds may not make loans to other persons, except as allowed by applicable law
including the 1940 Act and published SEC staff positions.
Further Explanation of Lending Policy. The acquisition of investment securities or other investment instruments, entering
into repurchase agreements, leaving cash on deposit with the Funds' custodian, and
similar actions are not deemed to be the making of a loan.
To generate income and offset expenses, the Funds may lend portfolio securities to
broker-dealers and other financial institutions that the Adviser believes to be creditworthy in an amount up to 33 1∕3% of its total assets, taken at market value. While securities are on loan, the borrower will pay the Funds any income accruing
on the security. The Funds may invest any collateral it receives in additional portfolio securities, typically U.S. Treasury
notes, certificates of deposit, other high-grade, short-term obligations, or interest-bearing cash equivalents. The Funds are still
subject to gains or losses due to changes in the value of securities that they have lent.
When the Funds lend their securities, they will require the borrower to give the Funds
collateral in cash or U.S. Government securities. The Funds will require collateral in an amount equal to
at least 100% of the current value of the securities lent, including accrued interest. The Funds have the right to call
a loan and obtain the securities lent any time on notice of not more than five business days. The Funds may pay reasonable fees in
connection with such loans.
Non-Fundamental Investment Policies
The Funds have adopted and will follow the non-fundamental investment policies set
forth below which may be changed by the Funds' Board of Trustees without the approval of the Funds' shareholders.
◼
Liquidity. The Funds shall be invested in publicly traded or otherwise readily marketable equity
securities. A security may become illiquid after purchase. If this occurs the Adviser would attempt to liquidate a Fund’s investment in this illiquid security in an orderly fashion.
◼
High-Yield, High-Risk Securities. The Funds will not purchase debt securities rated BB or Ba or lower (sometimes referred
to as “Junk Bonds”) if the securities are in default at the time of purchase or if such purchase would then cause more than 20% of the Funds' net assets to be invested in such lower-rated securities.
◼
Short Selling. A Fund will not sell any security short if it would cause more than 5% of its total
assets, taken at market value, to be sold short. This limitation does not apply to selling short against the
box.
◼
Investing for Control. The Funds do not invest for the purpose of exercising control or management of other
companies.
◼
Mortgage, Pledge, Lend or Hypothecate Assets. A Fund will not mortgage, pledge, lend, or hypothecate more than 33 1∕3% of its total assets, taken at market value, in securities lending or other activities.
◼
Name Policy. Under normal circumstances, Davis Select Financial ETF invests at least 80% of net
assets, plus any borrowing for investment purposes, in securities issued by companies principally engaged
in the financial services sector. Under normal circumstances, Davis Select U.S. Equity ETF invests at least 80% of net
assets plus any borrowing for investment purposes in equity securities issued by U.S. companies. Under normal circumstances,
Davis Select Worldwide ETF and Davis Select International ETF will invest at least 40% of net assets in securities
issued by companies (1) organized or located outside of the U.S.; (2) whose primary trading market is located
outside the U.S.; or (3) doing a substantial amount of business outside the U.S., which the Fund considers to be a
company that derives at least 50% of its revenue from business outside the U.S. or has at least 50% of its assets outside the
U.S. Each Fund will comply with its Name Policy as of the time an investment is made. If at some point a Fund no longer
meets the 80% test (e.g., due to value changes), it would not be required to sell assets, although any future investments
would need to be made in a manner that tends to bring the Fund back into compliance. In addition, because the 80% test applies under “normal circumstances,” a Fund could depart from the 80% requirement to take temporary defensive positions or
due to other unusual events.
Davis Select U.S. Equity ETF, Davis Select Financial ETF, Davis Select International
ETF or Davis Select Worldwide ETF would provide Fund shareholders with at least 60 days’ prior notice before changing its Name Policy, as described above.
Exchange Listing and Trading
A discussion of exchange listing and trading matters associated with an investment
in a Fund is contained in the prospectus under “Buying and Selling Shares.” The discussion below supplements, and should be read in conjunction with, such section of the prospectus.
The shares of a Fund are approved for listing and trading on the Exchange, subject
to notice of issuance. The shares trade on the Exchange at prices that may differ from their NAV. There can be no assurance that
the requirements of the Exchange necessary to maintain the listing of shares of a Fund will continue to be met.
Statement of Additional Information | Davis ETFs | 20
The Exchange may, but is not required to, remove the shares of a Fund from listing
if: (1) a Fund is no longer eligible to operate in reliance on Rule 6c-11 under the Investment Company Act of 1940; (2) if
following the initial twelve-month period beginning upon the commencement of trading of a Fund, there are fewer than 50 beneficial
holders of the shares for 30 or more consecutive trading days; (3) if any of the other listing requirements are not
continuously maintained; (4) if a Fund has failed to file any filings required by the SEC or it is not in compliance with any
exemptive order or no-action relief granted by the commission; or (5) such other event shall occur or condition exists that, in the
opinion of the Exchange, makes further dealings on the Exchange inadvisable. In addition, the Exchange will remove the shares
from listing and trading upon termination of the Trust or a Fund.
The Trust reserves the right to adjust the share price of a Fund in the future to
maintain convenient trading ranges for investors. Any adjustments would be accomplished through stock splits or reverse stock splits,
which would have no effect on the net assets of the Fund.
As in the case of other publicly traded securities, brokers’ commissions on transactions will be based on negotiated commission rates at customary levels.
The base and trading currencies of the Funds is the U.S. dollar. The base currency is the currency in which the Funds’ NAV per share is calculated and the trading currency is the currency in which shares of
the Funds are listed and traded on the Exchange.
Statement of Additional Information | Davis ETFs | 21
Section II:
The Trust and Key Persons
The Trust and Key Persons
This SAI should be read in conjunction with the prospectus. This SAI supplements the
information available in the prospectus.
Organization of the Trust
The Trust. Davis Fundamental ETF Trust is a business trust established in Delaware in 2016 and
registered under the 1940 Act. The Trust may issue multiple series, each of which would represent an interest
in its separate portfolio. Currently, there are four series: (1) Davis Select U.S. Equity ETF (“DUSA”); (2) Davis Select Financial ETF (“DFNL”); (3) Davis Select International ETF (“DINT”); and (4) Davis Select Worldwide ETF (“DWLD”). For some issues, such as the election of
Trustees, all of the Trust’s authorized series vote together. For other issues, such as approval of the advisory agreement, each authorized series votes separately. Shares do not have cumulative voting rights. Therefore,
the holders of more than 50% of the voting power can elect all of the Trustees. Rule 18f-2 under the 1940 Act provides
that any matter required to be submitted under the provisions of the 1940 Act or applicable state law or otherwise to the shareholders
of the outstanding voting securities of an investment company will not be deemed to have been effectively acted
on unless approved by the holders of a majority of the outstanding shares of each series affected by such matter. Rule 18f-2
further provides that a series shall be deemed to be affected by a matter unless it is clear that the interests of each series
in the matter are identical or that the matter does not affect any interest of such series. Rule 18f-2 exempts the selection of independent
accountants and the election of members of the Board of Trustees from the separate voting requirements of the Rule.
The Trust does not hold regular annual shareholder meetings. Shareholder meetings
are held when they are required under the 1940 Act or when otherwise called for special purposes. Special shareholder meetings
may be called on the written request of shareholders of at least 2∕3 of the voting power that could be cast at the meeting. The Funds will provide assistance
in calling and holding such special meetings to the extent required by applicable Delaware law
or SEC rules and regulations then in effect.
Trustees and Officers
The management of the Trust, including general supervision of the duties performed
for the Funds by the Adviser under the Investment Management Agreement, is the responsibility of the Board of Trustees (the “Board”). The Board is comprised of three members, one of whom is an “interested person” (as such term “interested person” is defined in the 1940 Act) and two of whom are not interested persons (referred to herein as “Independent Trustees”). One Independent Trustee was previously an Officer to the Adviser and its affiliates. The Board establishes each Fund’s policies and meets regularly to review the activities of the Officers, who are responsible for day-to-day operations of the Funds,
the Adviser, and certain other service providers. The Board approves all significant agreements between each Fund and those
companies that furnish services to the Funds. Trustees are elected and serve until their successors are elected and qualified.
Information about the Trustees, including their business addresses, dates of birth, principal occupations during the past five
years and other current Directorships of publicly traded companies or funds, are set forth in the table below.
Kenneth Eich serves as the Chairman of the Board. The Independent Trustees have designated
a Lead Independent Trustee, who functions as a liaison between the Chairman of the Board and the other Independent
Trustee(s). The Lead Independent Trustee presides at all Executive Sessions of the Independent Trustees, reviews and
provides input on Board meeting agendas and materials, and typically represents the Independent Trustees in discussions with
Davis Advisors management. Ralph Egizi currently serves as Lead Independent Trustee. The Board has reviewed and determined
that its leadership and committee structure is appropriate. The Chairman may perform such other functions as may be
requested by the Board from time to time. The Board has designated a number of standing committees, as further described below,
each of which has a Chairman. The Board also may designate working groups or ad hoc committees as it deems appropriate.
The Board believes that this leadership structure is appropriate because it allows
the Board to exercise informed and independent judgment over matters under its purview and it allocates areas of responsibility
among committees or working groups of Trustees and the full Board in a manner that enhances effective oversight.
The Board also believes that having a majority of Independent Trustees is appropriate and in the best interest of each Fund’s shareholders. Nevertheless, the Board also believes that having interested persons serve on the Board brings corporate and
financial viewpoints that are, in the Board’s view, crucial elements in its decision-making process. The leadership structure of the Board may be changed at any time and at the discretion of the Board, including in response to changes in circumstances
or the characteristics of the Funds.
Trustees
For the purposes of their service as Trustees to the Trust, the business address for
each of the Trustees is: 2949 East Elvira Road, Suite 101, Tucson, AZ 85756.
Statement of Additional Information | Davis ETFs | 22
|
Name, Date of Birth,
Position(s) Held with
Fund, Length of Service
|
Principal Occupation(s) During Past 5
Years
|
Number of
Portfolios
Overseen
|
Other Directorships Held by Trustee
During the Past 5 Years
|
|
Independent Trustees:
|
|
|
|
|
Ralph J. Egizi
(03/31/1948)
Trustee since 2016
|
President, EGZ International, LLC
(investment and financial consulting
company); Director, Benefits Finance and
Investments, Eastman Chemical Company
(manufacturer of chemicals, fibers and
plastics), from 1999 to 2013.
|
4
|
None
|
|
Lawrence Harris
(09/16/56)
Trustee since 2025
|
Fred V. Keenan Chair in Finance of the
Marshall School of Business, University of
Southern California, Los Angeles, CA.
|
4
|
Director, Interactive Brokers Group,
Inc.; Director, Selected Fund
(consisting of two portfolios), from
2015 to 2024; Trustee, Clipper Funds
Trust (consisting of one portfolio),
from 2006 to 2024.
|
|
Thomas D. Tays
(03/07/1957)
Trustee since 2016
|
Retired. Chief Legal Officer, Davis Selected
Advisers, L.P. from 1997 to 2013.
|
4
|
None
|
|
Interested Trustee:
|
|
|
|
|
Kenneth C. Eich
(08/14/1953)
Trustee since 2016
|
Chief Operating Officer, Davis Selected
Advisers, L.P.
|
4
|
None
|
Independent Trustees’ Compensation
Independent Trustees receive an annual retainer for their service. During the fiscal
year-ended October 31, 2025, the compensation paid to the Trustees who are not considered to be interested persons
of the Funds is listed in the table below. The Trustees receive no pecuniary retirement benefits accrued as Fund expenses. Interested
Trustees are not compensated by the Funds.
|
Independent
Trustees
|
DUSA
|
DFNL
|
DWLD
|
DINT
|
Aggregate Fund
Compensation(1)
|
Total Complex
Compensation(2)
|
|
Ralph J. Egizi
|
$11,719
|
$4,588
|
$6,778
|
$3,915
|
$27,000
|
$27,000
|
|
Lawrence Harris
|
$9,242
|
$3,566
|
$5,215
|
$2,977
|
$21,000
|
$28,810
|
|
Thomas D. Tays
|
$11,719
|
$4,588
|
$6,778
|
$3,915
|
$27,000
|
$27,000
|
(1)
“Aggregate Fund Compensation” is the aggregate compensation paid for service as a Trustee by all series of the Trust.
(2)
“Total Complex Compensation” is the aggregate compensation paid for service as a Trustee by all mutual funds with the same investment adviser. There are seven registered investment companies in the complex.
Officers
All Davis ETFs officers (including the Interested Trustee/Chairman) hold positions
as executive officers with the Adviser and its affiliates, including Davis Selected Advisers, L.P. (Adviser), Davis Selected Advisers–NY, Inc. (sub-adviser), Davis Distributors, LLC (the principal underwriter to the Davis Funds, Selected Fund, and
Clipper Fund), Davis Investments, LLC (the sole general partner of the Adviser), and other affiliated companies. The Davis
ETFs do not pay salaries to any of their officers. Each of the Davis ETFs' officers is elected annually. Davis ETFs' officers
serve until reelection or until their successor is elected and qualified.
Lisa Cohen (born 04/25/89, Officer of Davis Fundamental ETF Trust since 2021). Vice President and Secretary of Davis New York Venture Fund, Inc., Davis Variable Account Fund, Inc., and Davis Series, Inc. (collectively, the “Davis Funds,” consisting of thirteen portfolios), Selected American Shares, Inc. (consisting of
one portfolio), Clipper Funds Trust (consisting of one portfolio), and Davis Fundamental ETF Trust (consisting of four portfolios);
Vice President, Chief Legal Officer, and Secretary of Davis Selected Advisers, L.P.; and also serves as an executive officer
of certain companies affiliated with the Adviser. Prior to assuming these positions, Ms. Cohen worked for Honeywell International, Inc. (January 2020 – June 2021) and as an attorney at Davis Selected Advisers, L.P. (December 2015 – January 2020).
Christopher Davis (born 07/13/65, Officer of Davis Fundamental ETF Trust since 2016). President of Davis New York Venture Fund, Inc., Davis Variable Account Fund, Inc., and Davis Series, Inc. (collectively, the “Davis Funds,” consisting of thirteen portfolios), Selected American Shares, Inc. (consisting of one portfolio),
Clipper Funds Trust (consisting of one portfolio), and Davis Fundamental ETF Trust (consisting of four portfolios); Director/Trustee
Davis Funds, Selected Fund and Clipper Fund; Chairman of Davis Selected Advisers, L.P.; and also serves as an executive
officer of certain companies affiliated with the Adviser, including sole member of the Adviser’s general partner, Davis Investments, LLC.
Kenneth Eich (born 08/14/53, Officer of Davis Fundamental ETF Trust since 2016). Executive Vice President and Principal Executive Officer of Davis New York Venture Fund, Inc., Davis Variable Account Fund,
Inc., and Davis Series, Inc. (collectively, the “Davis Funds,” consisting of thirteen portfolios), Selected American Shares, Inc. (consisting of one
Statement of Additional Information | Davis ETFs | 23
portfolio), and Clipper Funds Trust (consisting of one portfolio); Trustee/Chairman,
Executive Vice President, and Principal Executive Officer of Davis Fundamental ETF Trust (consisting of four portfolios);
Chief Operating Officer of Davis Selected Advisers, L.P.; and also serves as an executive officer of certain companies affiliated
with the Adviser.
Douglas Haines (born 03/04/71, Officer of Davis Fundamental ETF Trust since 2016).
Vice President, Treasurer, Chief Financial Officer, Principal Financial Officer, and Principal Accounting Officer of
Davis New York Venture Fund, Inc., Davis Variable Account Fund, Inc., and Davis Series, Inc. (collectively, the “Davis Funds,” consisting of thirteen portfolios), Selected American Shares, Inc. (consisting of one portfolio), Clipper Funds Trust (consisting
of one portfolio), and Davis Fundamental ETF Trust (consisting of four portfolios); Vice President and Director of Fund Accounting
of Davis Selected Advisers, L.P.
Michaela McLoughry (born 03/21/81, Officer of Davis Fundamental ETF Trust since 2023). Vice President and Chief Compliance Officer of Davis New York Venture Fund, Inc., Davis Variable Account Fund,
Inc., and Davis Series, Inc. (collectively, the “Davis Funds,” consisting of thirteen portfolios), Selected American Shares, Inc. (consisting of one portfolio), Clipper Funds Trust (consisting of one portfolio), and Davis Fundamental
ETF Trust (consisting of four portfolios); Vice President and Chief Compliance Officer of Davis Selected Advisers, L.P.; and
also serves as an executive officer of certain companies affiliated with the Adviser. Prior to assuming these positions,
Ms. McLoughry spent approximately 18 years in the Fund Accounting department at Davis Selected Advisers, L.P.
Jeffrey Pittman (born 03/03/72, Officer of Davis Fundamental ETF Trust since 2021). Assistant Secretary of the Davis Fundamental ETF Trust (consisting of four portfolios); Assistant Secretary of Davis
Selected Advisers, L.P., and also serves as an executive officer of certain companies affiliated with the Adviser. Prior to assuming
these positions, Mr. Pittman spent 12 years in the Legal department at Davis Selected Advisers, L.P.
Standing Committees of the Board of Trustees
Although the Board has general criteria that guide its choice of candidates to serve
on the Board, there are no specific required qualifications for Board membership, including with respect to the diversity of candidates
for Board membership. Candidates for Board membership nominated by shareholders are not treated differently than candidates
nominated from other sources. The Board believes that the different perspectives, viewpoints, professional experience,
education and individual qualities of each Trustee represent a diversity of experiences and a variety of complementary skills. It is the Trustees’ belief that this allows the Board, as a whole, to oversee the business of each Fund in a manner consistent with the best interests of the Fund’s shareholders. When considering potential nominees to fill vacancies on the Board,
and as part of its annual self-evaluation, the Board reviews the mix of skills and other relevant experiences of the Trustees; qualified
candidates will be people of proven character and talent who have achieved notable success in their professional careers.
The specific talents that the Nominating Committee of the Board seeks in a candidate depend to a great extent upon the Board’s needs at the time a vacancy occurs.
The table above provides the professional experience of each Trustee on an individual
basis. This disclosure includes the length of time serving the Funds, other directorships held and their principal occupation
during the past five years. Each of the Trustees has spent a significant amount of their professional career working with
registered investment companies. For this reason they have become familiar with the regulatory and investment matters that may
impact the Funds. This experience contributes to the Trustees’ deliberations. In light of the Funds’ business and structure, the Board believes the experience of each Trustee is beneficial for overseeing the business of each Fund. Moreover, the
Board believes that the different experiences and backgrounds of the Trustees are complementary and enhance the Board’s ability to oversee the each Fund’s affairs.
Audit Committee. The Board of Trustees has established an Audit Committee, which is comprised entirely
of Independent Trustees (Thomas Tays, Chair; Ralph Egizi; and Lawrence Harris). The Audit Committee
has a charter. The Audit Committee reviews financial statements and other audit-related matters for the Trust. The Audit
Committee also holds discussions with management and with the Independent Accountants concerning the scope of the audit and the auditor’s independence. The Audit Committee meets as often as deemed appropriate by the Audit Committee. The Audit
Committee met four times during the fiscal year ended October 31, 2025.
The Board of Trustees has determined that Thomas Tays is the Trust’s Independent Audit Committee Financial Expert, pursuant to Section 407 of the Sarbanes-Oxley Act and as defined by Item 3 of Form
N-CSR of the 1940 Act. In their deliberations, the Board of Trustees considered Mr. Tays’ (1) professional experience; (2) independence as defined in Item 3 of Form N-CSR; and (3) integrity and absence of disciplinary history.
Nominating Committee. The Board of Trustees has established a Nominating Committee, which is comprised
entirely of Independent Trustees (Ralph Egizi, Chair; and Thomas Tays), which meets as often as
deemed appropriate by the Nominating Committee. The Funds do not elect Trustees annually. Each Trustee serves until retirement,
resignation, death or removal. Trustees must retire at the end of the calendar year in which they turn 74, with the
founding Board members exempted. The Nominating Committee met two times during the fiscal year ended October 31, 2025.
The Nominating Committee reviews and nominates persons to serve as members of the Board of Trustees, and reviews and makes
recommendations concerning the compensation of the Independent Trustees. The Chairperson of the Nominating Committee
(1) presides over Executive Sessions of the Independent Trustees of the Funds, in addition to presiding over meetings
of the committee; (2) participates with the officers and counsel in the preparation of agendas and materials for Board
meetings; (3) facilitates communication between the Independent Trustees and management, and among the Independent Trustees;
and (4) has such other responsibilities as the Board or Independent Trustees shall determine. The Nominating
Committee has a charter. When the
Statement of Additional Information | Davis ETFs | 24
Board is seeking a candidate to become a Trustee, it considers qualified candidates
received from a variety of sources, including having authority to retain third parties that may receive compensation related
to identifying and evaluating candidates. Shareholders may propose nominees by writing to the Nominating Committee,
in care of the Secretary of the Davis Fundamental ETF Trust, at 2949 East Elvira, Suite 101, Tucson, Arizona 85756.
Brokerage Committee. The Board of Trustees has established a Brokerage Committee, which is comprised entirely
of Independent Trustees (Ralph Egizi, Chair; and Thomas Tays), which meets as often as
deemed appropriate by the Brokerage Committee. The Brokerage Committee met one time during the fiscal year-ended October
31, 2025. The Brokerage Committee reviews and makes recommendations concerning the Trust’s portfolio brokerage and trading practices.
Risk Oversight
Registered investment companies, including Davis ETFs, are subject to a variety of
risks, including investment risk, valuation risk, reputational risk, risk of operational failure or lack of business continuity,
and legal, compliance, and regulatory risk. Risk management seeks to identify and address risks, i.e., events or circumstances
that could have material adverse effects on the business, operations, shareholder services, investment performance or reputation
of the Funds.
Day-to-day management of Davis ETFs, including risk management, is the responsibility
of the Davis ETFs' contractual service providers, including the Funds' Adviser, Sub-Adviser, as applicable, the Distributor,
Custodian and Transfer Agent. Each of these entities is responsible for specific portions of the Funds' operations
including the processes and associated risks relating to the Funds' investments, integrity of cash movements, financial reporting,
operations, and compliance. The Board of Trustees oversees the service providers’ discharge of their responsibilities including the processes they use to manage relevant risks. As part of its overall activities, the Board of Trustees reviews the
management of the Funds' risk management structure by various departments of the Adviser including: Portfolio Management, Fund
Operations, Legal, and Internal Audit, as well as by Davis ETFs' Chief Compliance Officer (“CCO”). The responsibility to manage the Funds' risk management structure on a day-to-day basis is within the Adviser’s overall investment management responsibilities. The Adviser has its own, independent interest in risk management.
The Board of Trustees discharges risk oversight as part of its overall activities
with the assistance of its Audit Committee and CCO. In addressing issues regarding the Funds' risk management between meetings, appropriate
representatives of the Adviser communicate with the Chair of the Board of Trustees or Davis ETFs' CCO, who
is accountable and reports directly to the Board of Trustees. Various personnel, including Davis ETFs' CCO, the Adviser’s management, and other service providers (such as the Funds' independent accountants) make periodic reports to the Board of
Trustees or to the Audit Committee with respect to various aspects of risk management.
The Board of Trustees recognizes that not all risks that may affect the Funds can
be identified, that it may not be practical or cost-effective to eliminate or mitigate certain risks, that it may be necessary to
bear certain risks (such as investment-related risks) to achieve the Funds' investment objectives, and that the processes, procedures,
and controls employed to address certain risks may be limited in their effectiveness. Moreover, reports received by
the Trustees as to risk management matters are typically summaries of the relevant information. As a result of the foregoing and other factors, the Board of Trustees’ risk management oversight is subject to substantial limitations.
The Audit Committee assists the Board of Trustees in reviewing with the independent
auditors, at various times throughout the year, matters relating to the annual audits and financial accounting and reporting
matters.
Davis ETFs' CCO assists the Board of Trustees in overseeing the significant investment
policies of the Funds. The CCO monitors these policies. The Board of Trustees receives and considers the CCO’s annual written report which, among other things, summarizes material compliance issues that arose during the previous year
and any remedial action taken to address these issues, as well as any material changes to the compliance programs. The Board
of Trustees also receives and considers reports from Davis ETFs' CCO throughout the year. As part of its oversight responsibilities,
the Board of Trustees has approved various compliance policies and procedures. Each Committee presents reports
to the Board of Trustees which may prompt further discussion of issues concerning the oversight of the Funds' risk management.
The Board of Trustees also may discuss particular risks that are not addressed in the Committee process.
Trustees’ Fund Holdings
As of December 31, 2025, the Trustees had invested the following amounts in all Funds
managed by the Adviser. Investments are listed in the following ranges: None, $1–10,000, $10,001–50,000, $50,001–100,000 and Over $100,000:
|
Independent Trustees
|
DUSA
|
DFNL
|
DINT
|
DWLD
|
Total Invested in All
Funds(1)
|
|
Ralph J. Egizi
|
None
|
$1-10,000
|
$1-10,000
|
$1-10,000
|
$1-10,000
|
|
Lawrence Harris
|
$10,000-50,000
|
$10,000-50,000
|
$10,000-50,000
|
$10,000-50,000
|
Over $100,000
|
|
Thomas Tays
|
$10,000-50,000
|
$10,000-50,000
|
$10,000-50,000
|
$10,000-50,000
|
$50,001-100,000
|
|
Interested Trustee(2)
|
|
|
|
|
|
|
Kenneth Eich
|
$50,001-100,000
|
$50,001-100,000
|
$50,001-100,000
|
$50,001-100,000
|
Over $100,000
|
(1)
“Total Invested in All Funds” is the aggregate dollar range of investments in all Funds overseen by the individual Trustee and managed by Davis Selected Advisers, L.P. This includes the Davis Funds, Selected Fund, and Clipper
Fund.
Statement of Additional Information | Davis ETFs | 25
(2)
Interested Trustees are employed by and own shares in the Adviser and are considered to be “interested persons” of the Davis ETFs as defined in the 1940 Act.
Independent Trustees’ Affiliations and Transactions
None of the Independent Trustees (or their immediate family members) own any securities issued by the Trust’s investment adviser, sub-adviser, principal underwriter or any company (other than a registered
investment company) directly or indirectly controlling, controlled by or under common control with the above listed companies (hereafter, referred to as the “Adviser and its affiliates”). Mr. Eich owns partnership units (directly, indirectly or both) in the Adviser and is considered to be an Interested Trustee.
None of the Independent Trustees (or their immediate family members) have had any
direct or indirect interest, the value of which exceeds $120,000, during the last two calendar years in the Adviser or in the
Adviser and its affiliates.
None of the Independent Trustees (or their immediate family members) have had any
material interest in any transaction, or series of transactions, during the last two calendar years, in which the amount involved
exceeds $120,000 and to which any of the following persons was a party, including any Davis Fundamental ETF Trust, an officer
of the Davis Fundamental ETF Trust, or any fund managed by the Adviser or in the Adviser and its affiliates.
None of the Independent Trustees (or their immediate family members) have had any
direct or indirect relationships during the last two calendar years, in which the amount involved exceeds $120,000 and to which
any of the following persons was a party, including any Davis Fundamental ETF Trust, an officer of the Davis Fundamental ETF
Trust, or any fund managed by the Adviser or in the Adviser and its affiliates.
None of the officers of the Adviser and its affiliates have served during the last
two calendar years on the board of directors/trustees of a company where any Trustee of the Funds (or any of the Trustees’ immediate family members) served as an officer.
Certain Shareholders of the Funds
As of February 2, 2026, the Funds' Trustees and Officers, as a group, owned the following
percentages of shares issued by the Funds. This percentage does not include investments controlled indirectly, including
holdings by Davis Selected Advisers, L.P.
An Authorized Participant may hold of record more than 25% of the outstanding shares
of each Fund. From time to time, Authorized Participants may be a beneficial and/or legal owner of a Fund, may be affiliated
with an index provider, may be deemed to have control of a Fund and/or may be able to affect the outcome of matters
presented for a vote of the shareholders of a Fund. Authorized Participants may execute an irrevocable proxy granting the Distributor
or an affiliate of the Distributor (the “Agent”) the power to vote or abstain from voting such Authorized Participant’s beneficially or legally owned shares of a Fund. In such cases, the Agent shall mirror vote (or abstain from voting) such shares
in the same proportion as all other beneficial owners of the voting Fund.
|
|
Officers and Trustees
|
|
Davis Select U.S. Equity ETF
|
*
|
|
Davis Select Financial ETF
|
*
|
|
Davis Select Worldwide ETF
|
*
|
|
Davis Select International ETF
|
*
|
*
Indicates that officers and directors as a group owned less than 1% of the outstanding
shares of the indicated class of shares.
The following table sets forth, as of February 2, 2026, the name and holdings of each
person known by Davis Fundamental ETF Trust, to be a record owner of more than 5% of the outstanding shares of the Funds.
Other than as indicated below, the Funds are not aware of any shareholder who beneficially owns more than 25% of the
Funds' total outstanding shares. Shareholders owning a significant percentage of the Funds' shares do not affect the
voting rights of other shareholders.
|
|
Name of Shareholders
Owning More Than 5% of Fund
|
Percent
Outstanding
|
|
DUSA
|
Morgan Stanley
|
26.16%
|
|
|
Davis Advisors
|
17.18%
|
|
|
Merrill
|
10.00%
|
|
|
National Financial Services
|
9.43%
|
|
|
Raymond James
|
6.89%
|
|
|
LPL Financial
|
5.91%
|
|
|
Charles Schwab
|
5.76%
|
Statement of Additional Information | Davis ETFs | 26
|
|
Name of Shareholders
Owning More Than 5% of Fund
|
Percent
Outstanding
|
|
DFNL
|
National Financial Services
|
25.13%
|
|
|
Davis Advisors
|
21.91%
|
|
|
Morgan Stanley
|
14.02%
|
|
|
CharlesSchwab
|
8.43%
|
|
|
LPL Financial
|
6.38%
|
|
DWLD
|
Morgan Stanley
|
20.21%
|
|
|
Davis Advisors
|
17.13%
|
|
|
BNY Pershing
|
15.07%
|
|
|
Charles Schwab
|
7.21%
|
|
|
LPL Financial
|
6.57%
|
|
|
National Financial Services
|
6.29%
|
|
|
Stifel
|
5.18%
|
|
DINT
|
Davis Advisors
|
41.55%
|
|
|
Charles Schwab
|
14.13%
|
|
|
Raymond James
|
9.44%
|
|
|
Stifel
|
6.37%
|
|
|
Morgan Stanley
|
5.66%
|
Investment Advisory Services
Davis Selected Advisers, L.P. and Davis Selected Advisers–NY, Inc. Davis Selected Advisers, L.P. (the “Adviser”), whose principal office is at 2949 East Elvira Road, Suite 101, Tucson, Arizona 85756, serves
as investment adviser for each Fund. The Adviser is also responsible for managing each Fund’s business affairs and providing day-to-day administrative services to the Funds. The Adviser also provides advisory or sub-advisory services to other parties
including other registered investment companies, private accounts, offshore funds and managed money/wrap accounts. Davis
Investments, LLC, an entity controlled by Christopher Davis, is the Adviser’s sole general partner. Mr. Davis is Chairman of the Adviser and, as the sole member of the general partner, controls the Adviser. Davis Selected Advisers – NY, Inc., a wholly owned subsidiary of the Adviser, serves as sub-adviser to and performs investment management, research and other services
for the Davis Fundamental ETF Trust on behalf of the Adviser, under the agreement with the Adviser. All fees paid to the
Sub-Adviser are paid by the Adviser.
Advisory Agreement with Davis Selected Advisers, L.P. and Sub-Advisory Agreement with Davis Selected Advisers–NY, Inc. Pursuant to an Advisory Agreement, each Fund pays the Adviser a fee at an annual rate
of 0.55% on its average net assets.
These fees may be higher than those of some other mutual funds but are not necessarily
higher than those paid by funds with similar objectives.
Expense Cap. The Adviser is contractually committed to waive fees and/or reimburse each Fund’s expenses to the extent necessary to cap total annual fund operating expenses at 0.65% for Davis Select U.S.
Equity ETF, Davis Select Financial ETF, and Davis Select Worldwide ETF and at 0.75% for Davis Select International ETF until
March 1, 2027. After that date, there is no assurance that the Adviser will continue to cap expenses.
The Funds paid the following aggregate advisory fees to the Adviser during the last
three fiscal years:
|
|
2025
|
2024
|
2023
|
|
Davis Select U.S. Equity ETF
|
$3,796,546
|
$2,611,995
|
$1,894,524
|
|
Davis Select International ETF
|
$1,244,736
|
$940,942
|
$847,327
|
|
Davis Select Worldwide ETF
|
$2,183,981
|
$1,624,231
|
$1,377,607
|
|
Davis Select Financial ETF
|
$1,478,203
|
$1,056,444
|
$922,870
|
For the fiscal year end periods shown below, the Adviser reimbursed the following
amounts:
|
|
2025
|
2024
|
2023
|
|
Davis Select U.S. Equity ETF
|
$0
|
$0
|
$0
|
|
Davis Select International ETF
|
$25,755
|
$66,127
|
$0
|
|
Davis Select Worldwide ETF
|
$0
|
$0
|
$0
|
|
Davis Select Financial ETF
|
$0
|
$0
|
$0
|
In accordance with the provisions of the 1940 Act, the Advisory Agreement and Sub-Advisory
Agreement will terminate automatically on assignment and are subject to cancellation on 60 days’ written notice by the Board of Trustees, the vote of the holders of a majority of the Funds' outstanding shares, or the Adviser. The continuance
of the Advisory Agreement and Sub-Advisory Agreement must be approved at least annually by the Funds' Board of Trustees
or by the vote of holders of a
Statement of Additional Information | Davis ETFs | 27
majority of the outstanding shares of the Funds. In addition, any new agreement or
the continuation of the existing agreement, must be approved by a majority of Trustees who are not parties to the agreements or
interested persons of any such party. The Advisory Agreement also makes provisions for portfolio transactions and brokerage
policies of the Funds, which are discussed above under “Portfolio Transactions.”
The Sub-Adviser performs research and other services on behalf of the Adviser. The Adviser pays all of the Sub-Adviser’s direct and indirect costs of operation. All fees paid to the Sub-Adviser are paid
by the Adviser and not the Funds.
Pursuant to the Advisory Agreement, the Adviser, subject to the general supervision of the Funds’ Board of Trustees, provides management and investment advice and furnishes statistical, executive and clerical
personnel, bookkeeping, office space and equipment necessary to carry out its investment advisory functions and such corporate
managerial duties as requested by the Board of Trustees of the Funds. The Funds bear all expenses other than those specifically
assumed by the Adviser under the Advisory Agreement, including preparation of its tax returns, financial reports to
regulatory authorities, dividend determinations, transactions and accounting matters related to its custodian bank,
transfer agency, custodial and investor services, and qualification of its shares under federal and state securities laws.
Approval of the Advisory and Sub-Advisory Agreements. The Board of Trustees is scheduled to meet four times a year. The Trustees believe that matters bearing on the Advisory and Sub-Advisory Agreements
are considered at most, if not all, of their meetings. The Independent Trustees are advised by independent legal counsel selected
by the Independent Trustees. A discussion of the Trustees’ considerations in the annual approval of Advisory and Sub-Advisory Agreements is included in the Funds' next annual or semi- annual report following the annual approval.
Unique Nature of Each Fund. The Adviser may serve as the investment adviser or sub-adviser to other funds that
have investment objectives and principal investment strategies similar to those of the
Funds. While the Funds may have many similarities to these other funds, the investment performance of each fund will be
different due to a number of differences between the funds including differences in expense ratios and cash flows.
Code of Ethics. The Adviser, Sub-Adviser, Distributor, and the Davis ETFs have adopted a Code of Ethics,
meeting the requirements of Rule 17j-1 under the 1940 Act that regulate the personal securities transactions of the Adviser’s investment personnel, other employees, and affiliates with access to information regarding securities
transactions of the Davis ETFs. Such employees may invest in securities including securities that may be purchased or held
by the Davis ETFs. A copy of the Code of Ethics is on public file with and available from the SEC.
Continuing Regulation. The Adviser, like most other asset managers, is subject to ongoing inquiries from
the SEC and/or the Financial Industry Regulatory Authority (“FINRA”) regarding industry practices.
Proxy Voting Policies and Record. The Board of Trustees has directed the Adviser to vote the Funds' portfolio securities
in conformance with the Adviser’s Proxy Voting Policies and Procedures. These policies and procedures are summarized in Appendix B. Information regarding how the Funds voted proxies relating to portfolio
securities during the most recent 12-month period ended June 30 is available, without charge, on the Funds' website, https://www.davisetfs.com/documents/Proxy_Voting_Policies.pdf, by calling Davis ETFs' Investor Services at 1-800-279-0279, or on the SEC’s website (www.sec.gov).
Portfolio Managers
Davis Select U.S. Equity ETF. The Portfolio Managers of Davis Select U.S. Equity ETF are Christopher Davis and Danton
Goei. They are the persons primarily responsible for investing the Fund’s assets on a daily basis.
Davis Select Financial ETF. The Portfolio Managers of Davis Select Financial ETF are Christopher Davis and Pierce
Crosbie. They are the persons primarily responsible for investing the Fund’s assets on a daily basis.
Davis Select Worldwide ETF & Davis Select International ETF. The Portfolio Manager of Davis Select Worldwide ETF and Davis Select International ETF is Danton Goei. Mr. Goei is the person primarily responsible for investing the Funds’ assets on a daily basis.
Accounts Managed as of October 31, 2025
|
Portfolio
Managers
|
Number of
RICs(1)
|
Assets(2) in
RICs
in millions
|
Number of
OPIV(3)
|
Assets in OPIV
in millions
|
Number of
OA(4)
|
Assets in OA
in millions
|
|
DUSA
|
|
|
|
|
|
|
|
Christopher Davis
|
10
|
$12,568.3
|
2
|
$509.0
|
35
|
$10,207.9
|
|
Danton Goei
|
10
|
$12,191.7
|
4
|
$763.8
|
33
|
$9,843.3
|
|
DFNL
|
|
|
|
|
|
|
|
Christopher Davis
|
10
|
$13,124.7
|
2
|
$509.0
|
35
|
$10,207.9
|
|
Pierce Crosbie
|
3
|
$1,244.0
|
0
|
$0
|
3
|
$874.0
|
|
DWLD
|
|
|
|
|
|
|
|
Danton Goei
|
10
|
$12,568.9
|
4
|
$763.8
|
33
|
$9,843.3
|
Statement of Additional Information | Davis ETFs | 28
|
Portfolio
Managers
|
Number of
RICs(1)
|
Assets(2) in
RICs
in millions
|
Number of
OPIV(3)
|
Assets in OPIV
in millions
|
Number of
OA(4)
|
Assets in OA
in millions
|
|
DINT
|
|
|
|
|
|
|
|
Danton Goei
|
10
|
$12,790.1
|
4
|
$763.8
|
33
|
$9,843.3
|
(1)
“RIC” means Registered Investment Company.
(2)
“Assets” means total assets managed by the Portfolio Manager. Some or all of these assets may be co-managed with another Portfolio Manager who will also be credited with managing the same assets. The sum of assets managed by Davis Advisors’ Portfolio Managers may exceed the total assets managed by Davis Advisors.
(3)
“OPIV” means Other Pooled Investment Vehicles.
(4)
“OA” means Other Accounts. These accounts are primarily private accounts and sponsors of managed money/wrap accounts.
Dollar Range of Fund Shares Owned as of October 31, 2025
|
Portfolio Managers
|
|
|
DUSA
|
|
|
Christopher Davis
|
$100,001–$500,000
|
|
Danton Goei
|
$100,001–$500,000
|
|
DFNL
|
|
|
Christopher Davis
|
Over $1 million
|
|
Pierce Crosbie
|
$100,001–$500,000
|
|
DINT
|
|
|
Danton Goei
|
Over $1 million
|
|
DWLD
|
|
|
Danton Goei
|
Over $1 million
|
Ownership disclosure is made using the following ranges: None; $1–$10,000; $10,001–$50,000; $50,001–$100,000; $100,001–$500,000; $500,001–$1 million; Over $1 million.
Structure of Compensation
Christopher Davis’ compensation for services provided to the Adviser consists of a base salary. The Adviser’s Portfolio Managers are provided benefits packages including life insurance, health insurance, and participation in the Adviser’s 401(k) plan comparable to that received by other company employees.
Danton Goei’s and Pierce Crosbie’s compensation for services provided to the Adviser consists of: (1) a base salary;
(2) an annual discretionary bonus; (3) awards of equity (“Units”) in Davis Selected Advisers, L.P., including Units and/or phantom Units; (4) an incentive plan whereby the Adviser purchases shares in certain mutual
funds managed by the Adviser, which vest based on the passage of time provided that the Portfolio Manager is still employed
by the Adviser; and (5) an incentive plan whereby the Adviser purchases shares in selected mutual funds managed by the Adviser.
In the case of fund shares purchased as described above in (5), at the end of specified periods, generally five-years following
the date of purchase, some, all, or none of the Fund shares will be registered in the employee’s name based on Fund performance, after expenses on a pre-tax basis, versus the Fund’s benchmark index, as described in the Fund’s prospectus or, in limited cases, based on performance ranking among established peer groups. The Adviser does not purchase incentive shares
in every fund these Portfolio Managers manage or assist on. In limited cases, such incentive compensation is tied
on a memorandum basis to the performance of the portion of the Fund (“sleeve”) managed by the analyst versus the Fund’s benchmark. The Adviser’s Portfolio Managers are provided benefits packages including life insurance, health
insurance, and participation in the Adviser’s 401(k) plan comparable to that received by other company employees.
Potential Conflicts of Interest
Potential conflicts of interest may arise in connection with the management of multiple
accounts, including potential conflicts of interest related to the knowledge and timing of Davis ETFs' trades, investment
opportunities, broker selection, and Fund investments. Portfolio Managers and other investment professionals may be privy to
the size, timing, and possible market impact of the Funds' trades. It is theoretically possible that Portfolio Managers
could use this information to the advantage of other accounts they manage and to the possible detriment of the Funds. It is possible
that an investment opportunity may be suitable for both the Funds and other accounts managed by Portfolio Managers but may
not be available in sufficient quantities for both the Funds and other accounts to participate fully. Similarly, there may be
limited opportunity to sell an investment held by the Funds and another account. Management of multiple portfolios and/or other
accounts may result in a Portfolio Manager devoting unequal time and attention to the management of each portfolio and/or
other accounts. The Adviser seeks to manage such competing interests for the time and attention of Portfolio Managers. For example, many of Davis Advisors’ Portfolio Managers focus on a small set of model accounts with similar accounts being
managed by investing in the same securities and using the same investment weightings that are used in connection with
the management of the model accounts.
If a Portfolio Manager identifies a limited investment opportunity which may be suitable
for more than one portfolio or other account, a portfolio may not be able to take full advantage of that opportunity due
to an allocation of filled purchase or sale orders across all eligible portfolios and other accounts. Large clients may generate
more revenue for the Adviser than do smaller accounts. Accounts which pay higher management fees usually generate more
revenue than accounts of the same size paying lower management fees. A Portfolio Manager may be faced with a conflict of
interest when allocating limited
Statement of Additional Information | Davis ETFs | 29
investment opportunities given the benefit to the Adviser of favoring accounts that
pay a higher fee or generate more income for the Adviser. To deal with these situations, the Adviser has adopted procedures
for allocating limited investment opportunities across multiple accounts.
With respect to securities transactions for the portfolios, the Adviser determines
which broker to use to execute each order, consistent with its duty to seek best execution of the transaction. However, with
respect to certain other accounts (such as mutual funds, other pooled investment vehicles that are not registered mutual funds,
and other accounts managed for organizations and individuals), the Adviser may be limited by the client with respect
to the selection of brokers or may be instructed to direct trades through a particular broker. In these cases, the Adviser
may place separate, non-simultaneous, transactions for a portfolio and another account which may temporarily affect the
market price of the security or the execution of the transaction, or both, to the detriment of the portfolio or the other account.
Substantial investment of the Adviser or Davis Family assets in certain mutual funds
may lead to conflicts of interest. A portion of a Portfolio Manager’s compensation may include awards of equity in Davis Advisors. A Portfolio Manager may face a conflict of interest given that the Adviser is more heavily invested in some funds
than in other funds. A portion of the Portfolio Manager’s compensation may also include an incentive plan whereby the Adviser purchases shares in certain funds managed by Davis Advisors. A Portfolio Manager may face a conflict of interest given
that their long-term compensation may be more heavily determined by the performance of one fund or portion of a fund than
by another fund which he also manages. To mitigate these potential conflicts of interest, the Adviser has adopted policies
and procedures intended to ensure that all clients are treated fairly over time. Davis Advisors does not receive an incentive
based fee on any account.
Davis Advisors expects that, over long periods of time, most clients pursuing similar
investment strategies should experience similar, but not identical, investment performance. Many factors affect investment
performance including, but not limited to: (1) the timing of cash deposits and withdrawals to and from an account; (2) the
possibility that Davis Advisors may not purchase or sell a given security on behalf of all clients pursuing similar strategies;
(3) price and timing differences when buying or selling securities; and (4) clients pursuing similar investment strategies
but imposing different investment restrictions. Davis Advisors has adopted written trading policies designed to minimize
possible conflicts of interest in trading for its clients.
Conflicts of interest may also arise regarding proxy voting. Davis Advisors has adopted
written proxy voting policies designed to minimize possible conflicts of interest when voting proxies on behalf of its clients.
Certain Portfolio Managers may serve on the board(s) of public companies where they,
from time to time, may have access to material, non-public information (“MNPI”). Davis Advisors has instituted policies and procedures to ensure that these Portfolio Managers will not be able to utilize MNPI for their own benefit or for any
of the accounts they manage.
Disclosure of Portfolio Holdings
Portfolio Holdings Information Is Protected. Information about the Funds' portfolio holdings is proprietary information which the Adviser is committed to protecting. Davis ETFs have adopted procedures reasonably
designed to ensure that portfolio holdings information is not released on a selective basis except to qualified
persons rendering services to the Funds which require that those persons receive information concerning the Funds' portfolio
holdings. Neither the Funds nor the Adviser receives compensation with respect to the disclosure of portfolio holdings.
Public Disclosure of Portfolio Holdings. The Trust has adopted a policy regarding the disclosure of information about the
Trust’s portfolio holdings. The Board must approve all material amendments to this policy. Each Fund’s portfolio holdings are publicly disseminated each day the Funds are open for business through financial reporting
and news services, including publicly accessible Internet web sites. In addition, a basket composition file, which
includes the security names and share quantities to deliver in exchange for shares, together with estimates and actual cash
components, is publicly disseminated daily prior to the opening of the Exchange via the National Securities Clearing Corporation (“NSCC”). The basket represents one Creation Unit of a Fund. The Trust, the Adviser, the Distributor and the Administrator
will not disseminate non-public information concerning the Trust, except information may be made available prior to
its public availability: (1) to a party for a legitimate business purpose related to the day-to-day operations of the Fund, including
(a) a service provider, (b) the stock exchanges upon which the ETF is listed, (c) the NSCC, (d) the Depository Trust Company (“DTC”), and (e) financial data/research companies such as Morningstar, Bloomberg L.P. and Reuters; or (2) to any other party
for a legitimate business or regulatory purpose, upon waiver or exception, with the consent of an applicable Trust
officer.
Book Entry Only System
The following information supplements, and should be read in conjunction with, the section in the Funds’ prospectus titled “Buying and Selling Shares.”
DTC acts as securities depositary for the shares. Shares of each Fund are represented
by securities registered in the name of DTC or its nominee and deposited with, or on behalf of, DTC. Except in the limited
circumstance provided below, certificates will not be issued for shares.
DTC, a limited-purpose trust company, was created to hold securities of its participants (the “DTC Participants”) and to facilitate the clearance and settlement of securities transactions among the DTC Participants
in such securities through electronic book-entry changes in accounts of the DTC Participants, thereby eliminating
the need for physical movement of
Statement of Additional Information | Davis ETFs | 30
securities certificates. DTC Participants include securities brokers and dealers,
banks, trust companies, clearing corporations and certain other organizations, some of whom (and/or their representatives) own DTC.
More specifically, DTC is owned by a number of its DTC Participants and by the New York Stock Exchange (“NYSE”) and FINRA. Access to the DTC system is also available to others, such as banks, brokers, dealers and trust companies that
clear through or maintain a custodial relationship with a DTC Participant, either directly or indirectly (the “Indirect Participants”).
Beneficial ownership of shares is limited to DTC Participants, Indirect Participants
and persons holding interests through DTC Participants and Indirect Participants. Ownership of beneficial interests in shares
(owners of such beneficial interests are referred to herein as “Beneficial Owners”) is shown on, and the transfer of ownership is effected only through, records maintained by DTC (with respect to DTC Participants) and on the records of DTC Participants
(with respect to Indirect Participants and Beneficial Owners that are not DTC Participants). Beneficial Owners
will receive from or through the DTC Participant a written confirmation relating to their purchase of shares.
Conveyance of all notices, statements and other communications to Beneficial Owners
is affected as follows. Pursuant to the Depositary Agreement between the Trust and DTC, DTC is required to make available
to the Trust, upon request and for a fee to be charged to the Trust, a listing of the shares of each Fund held by each DTC
Participant. The Trust, either directly or through a third-party service, shall inquire of each such DTC Participant as to the
number of Beneficial Owners holding shares, directly or indirectly, through such DTC Participant. The Trust, either directly
or through a third-party service, shall provide each such DTC Participant with copies of such notice, statement or other communication,
in such form, number and at such place as such DTC Participant may reasonably request, in order that such notice,
statement or communication may be transmitted by such DTC Participant, directly or indirectly, to such Beneficial Owners.
In addition, the Trust shall pay to each such DTC Participant and/or third party service a fair and reasonable amount as reimbursement
for the expenses attendant to such transmittal, all subject to applicable statutory and regulatory requirements.
Share distributions shall be made to DTC or its nominee as the registered holder of
all shares. DTC or its nominee, upon receipt of any such distributions, shall credit immediately DTC Participants’ accounts with payments in amounts proportionate to their respective beneficial interests in shares of each Fund as shown on the records
of DTC or its nominee. Payments by DTC Participants to Indirect Participants and Beneficial Owners of Shares held through
such DTC Participants will be governed by standing instructions and customary practices, as is now the case with
securities held for the accounts of customers in bearer form or registered in a “street name,” and will be the responsibility of such DTC Participants.
The Trust has no responsibility or liability for any aspects of the records relating
to or notices to Beneficial Owners, or payments made on account of beneficial ownership interests in such shares, or for
maintaining, supervising or reviewing any records relating to such beneficial ownership interests or for any other aspect of
the relationship between DTC and the DTC Participants or the relationship between such DTC Participants and the Indirect Participants
and Beneficial Owners owning through such DTC Participants. DTC may determine to discontinue providing its service
with respect to shares at any time by giving reasonable notice to the Trust and discharging its responsibilities with respect
thereto under applicable law. Under such circumstances, the Trust shall take action either to find a replacement for DTC to
perform its functions at a comparable cost or, if such a replacement is unavailable, to issue and deliver printed certificates
representing ownership of shares, unless the Trust makes other arrangements with respect thereto satisfactory to the Exchange.
Financial Statements
The audited financial statements and the report of the Funds' independent registered
public accounting firm, included in the Funds' Annual Financial Statements and Other Information, are incorporated by reference
into this SAI.
Other Important Service Providers
The Distributor. Foreside Fund Services, LLC, 3 Canal Plaza, Suite 100, Portland, Maine 04101, serves
as the Distributor for the Funds’ shares pursuant to a Distribution Agreement dated October 5, 2016 (the “Distribution Agreement”).
Pursuant to the Distribution Agreement, each Fund appointed the Distributor to be its agent for the distribution of the Fund’s shares on a continuous offering basis. Shares will be continuously offered for sale
by the Trust through the Distributor only in Creation Units, as described in the prospectus and below under “Purchase and Redemption of Creation Units.” Shares in less than Creation Units are not distributed by the Distributor. The Distributor will deliver
the prospectus to persons purchasing Creation Units and will maintain records of both orders placed with it and confirmations
of acceptance furnished by it. The Distributor is a broker-dealer registered under the Securities Exchange Act of 1934 (the “Exchange Act”) and a member of the Financial Industry Regulatory Authority (“FINRA”). The Distributor has no role in determining the investment policies of the Trust or which securities are to be purchased or sold by the Trust. The Distributor
may assist Authorized Participants in assembling shares to purchase Creation Units or upon redemption, for which it may
receive commissions or other fees from such Authorized Participants.
The Adviser and/or its affiliates may make payments to broker-dealers, registered
investment advisers, banks or other intermediaries (together, “intermediaries”) related to marketing activities and presentations, educational training programs, conferences, the development of technology platforms and reporting systems, or their
making shares of the Funds available to their customers generally and in certain investment programs. Such payments, which
may be significant to the intermediary, are not made by the Funds. Rather, such payments are made by the Adviser and/or its
affiliates from their own resources, which come directly or indirectly in part from fees paid by each Fund. Payments of
this type are sometimes referred to as revenue-sharing payments. A financial intermediary may make decisions about which
investment options it recommends or
Statement of Additional Information | Davis ETFs | 31
makes available, or the level of services provided, to its customers based on the
payments it is eligible to receive. Therefore, such payments to an intermediary create conflicts of interest between the intermediary
and its customers and may cause the intermediary to recommend a Fund over another investment.
Custodian. State Street Bank and Trust Company (“State Street” or the “Custodian”), One Congress Street, Suite 1, Boston, MA 02114-2016, serves as custodian of the Funds’ assets. The Custodian maintains all of the instruments representing each Fund’s investments and all cash.
Transfer Agent. State Street also serves as each Funds’ transfer agent.
Independent Registered Public Accounting Firm. KPMG LLP (“KPMG”), 191 W Nationwide Blvd, Suite 500, Columbus, OH 43215, serves as the Funds' independent registered public accounting firm. KPMG
audits the Funds' financial statements and financial highlights, performs other related audit services, and meets with the
Audit Committee of the Board of Trustees. KPMG also acts as the independent registered public accounting firm to certain other
funds advised by the Adviser. In addition, KPMG prepares the Funds' federal and state income tax returns and related
forms. Audit and non-audit services provided by KPMG to the Funds must be pre-approved by the Audit Committee.
Counsel. Greenberg Traurig, LLP, 1144 15th Street, Suite 3300, Denver, CO 80202, serves as
counsel to the Davis ETFs and also serves as counsel for the Independent Trustees.
Statement of Additional Information | Davis ETFs | 32
Section III:
Purchase and Redemption of Creation Units
Purchase and Redemption of Creation Units
This SAI should be read in conjunction with the Funds' prospectus. This SAI supplements
the information available in the Funds' prospectus.
Each Fund issues and redeems its shares on a continuous basis, at NAV, only in a large
specified number of shares called a “Creation Unit,” either principally in-kind for securities included in a Fund or in cash for the value of such securities. The value of each Fund is determined once each business day, as described under the “Valuation of Portfolio Securities” section in the Funds’ prospectus. The Creation Unit size for a Fund may change. Authorized Participants will be notified of such change. The principal consideration for creations and redemptions for a Fund is set forth
in the table below:
|
|
Creation*
|
Redemption*
|
|
Davis Select U.S. Equity ETF
|
In-Kind
|
In-Kind
|
|
Davis Select Financial ETF
|
In-Kind
|
In-Kind
|
|
Davis Select International ETF
|
In-Kind
|
In-Kind
|
|
Davis Select Worldwide ETF
|
In-Kind
|
In-Kind
|
* This may be revised at any time without notice.
Purchase (Creation). The Trust issues and sells shares of each Fund only in Creation Units on a continuous
basis through the Distributor, without a sales load (but subject to transaction fees), at their NAV
per share next determined after receipt of an order, on any Business Day (as defined below), in proper form pursuant to the terms
of the Authorized Participant Agreement (“Participant Agreement”). A “Business Day” with respect to a Fund is, generally, any day on which the NYSE is open for business. In some instances a Fund may accept an order to purchase shares on the next Business Day (a “T-1 Order”). A T-1 Order must be submitted in proper form to the Transfer Agent on the prior Business
Day in the manner set forth in the Participant Agreement and/or order form. The order cut off time is subject to change.
An Authorized Participant should consult with the Distributor.
Fund Deposit. The consideration for purchase of a Creation Unit of a Fund generally consists of
either (1) the in-kind deposit of a designated portfolio of securities (the “Deposit Securities”) per each Creation Unit, generally constituting a substantial replication, or a portfolio sampling representation, of the securities included in
a Fund and the Cash Component (defined below), computed as described below; or (2) the cash value of the Deposit Securities (“Deposit Cash”) and “Cash Component,” computed as described below. While the Deposit Securities will generally represent a pro-rata replication of the portfolio the Fund also reserves the right to require a custom basket of securities.
When accepting purchases of Creation Units for cash, a Fund may incur additional costs associated with the acquisition of Deposit
Securities that would otherwise be provided by an in-kind purchaser.
Together, the Deposit Securities or Deposit Cash, as applicable, and the Cash Component constitute the “Fund Deposit,” which represents the minimum initial and subsequent investment amount for a Creation Unit of a Fund. The “Cash Component,” which may include a Dividend Equivalent Payment, is an amount equal to the difference
between the NAV of the shares (per Creation Unit) and the value of the Deposit Securities or Deposit Cash, as applicable. The “Dividend Equivalent Payment” enables a Fund to make a complete distribution of dividends on the day preceding the
next dividend payment date, and is an amount equal, on a per Creation Unit basis, to the dividends on all the portfolio securities of a Fund (“Dividend Securities”) with ex-dividend dates within the accumulation period for such distribution (the “Accumulation Period”), net of expenses and liabilities for such period, as if all of the Dividend Securities had been held by
the Fund for the entire Accumulation Period. The Accumulation Period begins on the ex-dividend date for the Fund and ends on the
day preceding the next ex-dividend date. If the Cash Component is a positive number (i.e., the NAV per Creation Unit
exceeds the value of the Deposit Securities or Deposit Cash, as applicable), the Cash Component shall be such positive amount.
If the Cash Component is a negative number (i.e., the NAV per Creation Unit is less than the value of the Deposit Securities
or Deposit Cash, as applicable), the Cash Component shall be such negative amount and the creator will be entitled to receive
cash in an amount equal to the Cash Component. The Cash Component serves the function of compensating for any differences
between the NAV per Creation Unit and the value of the Deposit Securities or Deposit Cash, as applicable. Computation
of the Cash Component excludes any stamp duty or other similar fees and expenses payable upon transfer of beneficial
ownership of the Deposit Securities, if applicable, which shall be the sole responsibility of the Authorized Participant.
The Custodian, through NSCC, makes available on each Business Day, immediately prior
to the opening of business on the NYSE (currently 9:30 a.m., Eastern time), the list of the names and the required number
of shares of each Deposit Security or the required amount of Deposit Cash, as applicable, to be included in the current
Fund Deposit (based on information at the end of the previous Business Day) for the Fund. Such Fund Deposit is subject to any
applicable adjustments as described below, in order to effect purchases of Creation Units of the Fund until such time
as the next-announced composition of the Deposit Securities or the required amount of Deposit Cash, as applicable, is made
available.
The identity and number of shares of the Deposit Securities or the amount of Deposit
Cash, as applicable, required for a Fund Deposit for a Fund changes, as rebalancing adjustments, interest payments and corporate
action events are reflected from time to time by the Adviser with a view to the investment objective of a Fund. Information
regarding a Fund Deposit necessary for the purchase of a Creation Unit is made available to Authorized Participants and other
market participants seeking to transact
Statement of Additional Information | Davis ETFs | 33
in Creation Unit aggregations. The composition of the Deposit Securities may also
change in response to adjustments to the weighting or composition of the component securities of a Fund.
As noted above, the Trust reserves the right to permit or require the substitution
of Deposit Cash to replace any Deposit Security, which shall be added to the Cash Component, including, without limitation,
in situations where the Deposit Security (1) may not be available in sufficient quantity for delivery; (2) may not be eligible
for transfer through the systems of DTC for corporate securities and municipal securities or the Federal Reserve System for U.S.
Treasury securities; (3) may not be eligible for trading by an Authorized Participant or the investor for which it is
acting; (4) would be restricted under the securities laws or where the delivery of the Deposit Security to the Authorized Participant
would result in the disposition of the Deposit Security by the Authorized Participant becoming restricted under the securities
laws; or (5) in certain other situations (collectively, “non-standard orders”). The Trust also reserves the right to (1) permit or require the substitution of Deposit Securities in lieu of Deposit Cash; and (2) include or remove Deposit Securities
from the basket, such as for efficient tax management of the portfolio (“custom orders”). The adjustments described above will also reflect changes, known to the Adviser on the date of announcement to be in effect by the time of delivery of the
Fund Deposit, resulting from certain corporate actions.
Procedures for Purchase of Creation Units. To be eligible to place orders with the Distributor, as facilitated via the Transfer
Agent, to purchase a Creation Unit of a Fund, an entity must be (1) a “Participating Party” (i.e., a broker-dealer or other participant in the clearing process through the Continuous Net Settlement System of the NSCC)(the “Clearing Process”), a clearing agency that is registered with the SEC; or (2) a DTC Participant (see “Book Entry Only System”). In addition, each Participating Party or DTC Participant (each an “Authorized Participant”) must execute a Participant Agreement that has been agreed to by the Distributor and the Transfer Agent, and that has been accepted by
the Trust, with respect to purchases and redemptions of Creation Units. Each Authorized Participant will agree, pursuant to
the terms of a Participant Agreement, on behalf of itself or any investor on whose behalf it will act, to certain conditions,
including that it will pay to the Trust, an amount of cash sufficient to pay the Cash Component together with the creation transaction
fee (described below) and any other applicable fees, taxes and additional variable charge.
All orders to purchase shares directly from a Fund, including non-standard orders,
must be placed for one or more Creation Units and in the manner and by the time set forth in the Participant Agreement and/or
the applicable order form. Except in the case of a T-1 Order, the date on which an order to purchase Creation Units (or an
order to redeem Creation Units, as set forth below) is received and accepted is referred to as the “Order Placement Date.”
An Authorized Participant may require an investor to make certain representations
or enter into agreements with respect to the order (e.g., to provide for payments of cash, when required). Investors should be
aware that their particular broker may not have executed a Participant Agreement and that, therefore, orders to purchase shares
directly from a Fund in Creation Units have to be placed by the investor’s broker through an Authorized Participant that has executed a Participant Agreement. In such cases, there may be additional charges to such investor. At any given time, there
may be only a limited number of broker-dealers that have executed a Participant Agreement and only a small number of such Authorized
Participants may have international capabilities.
On days when the Exchange closes earlier than normal, a Fund may require orders to
create Creation Units to be placed earlier in the day. In addition, if a market or markets on which a Fund’s investments are primarily traded is closed, a Fund will also generally not accept orders on such day(s). Orders must be transmitted by an Authorized
Participant by telephone or other transmission method acceptable to the Distributor pursuant to procedures set forth
in the Participant Agreement and in accordance with the applicable order form. Those placing orders through an Authorized
Participant should allow sufficient time to permit proper submission of the purchase order by the cut-off time on such
Business Day. Economic or market disruptions or changes, or telephone or other communication failure may impede the
ability to reach the Distributor or an Authorized Participant.
Fund Deposits must be delivered by an Authorized Participant through the Federal Reserve
System (for cash and U.S. Government securities), or through DTC (for corporate securities and municipal
securities), through a sub-custody agent (for foreign securities) and/or through such other arrangements allowed by the Trust
or its agents. With respect to foreign Deposit Securities, the Custodian shall cause the sub-custodian of a Fund to maintain
an account into which the Authorized Participant shall deliver, on behalf of itself or the party on whose behalf it is
acting, such Deposit Securities. Foreign Deposit
Securities must be delivered to an account maintained at the applicable local sub-custodian.
The Fund Deposit transfer must be ordered by the Authorized Participant in a timely fashion so as to ensure the delivery
of the requisite number of Deposit Securities or Deposit Cash, as applicable, to the account of a Fund or its agents
by no later than the Settlement Date. The “Settlement Date” for a Fund is generally the third Business Day after the Order Placement Date. All questions as to the number of Deposit Securities or Deposit Cash to be delivered, as applicable, and the
validity, form and eligibility (including time of receipt) for the deposit of any tendered securities or cash, as applicable,
will be determined by the Trust, whose determination shall be final and binding. The amount of cash represented by the Cash
Component must be transferred directly to the Custodian through the Federal Reserve Bank wire transfer system in a timely
manner so as to be received by the Custodian no later than the Settlement Date. If the Cash Component and the Deposit
Securities or Deposit Cash, as applicable, are not received in a timely manner by the Settlement Date, the creation order may
be cancelled. Upon written notice to the Distributor, such canceled order may be resubmitted the following Business Day using
a Fund Deposit as newly constituted to
Statement of Additional Information | Davis ETFs | 34
reflect the then current NAV of a Fund. The delivery of Creation Units so created
generally will occur no later than the third Business Day following the day on which the purchase order is deemed received by the
Distributor.
The order shall be deemed to be received on the Business Day on which the order is
placed (except in the case of a T-1 Order as described herein), provided that the order is placed in proper form prior to the
applicable cut-off time and the federal funds in the appropriate amount are deposited by 2:00 p.m. or 3:00 p.m. Eastern time (per
applicable instructions) with the Custodian on the Settlement Date. If the order is not placed in proper form as required,
or federal funds in the appropriate amount are not received by 2:00 p.m. or 3:00 p.m. Eastern time (per applicable instructions)
on the Settlement Date, then the order may be deemed to be rejected and the Authorized Participant shall be liable
to the Fund for losses, if any, resulting therefrom. A creation request is considered to be in “proper form” if all procedures set forth in the Participant Agreement, order form and this SAI are properly followed.
Issuance of a Creation Unit. Except as provided herein, Creation Units will not be issued until the transfer of
good title to the Trust of the Deposit Securities or payment of Deposit Cash, as applicable, and the
payment of the Cash Component have been completed. When the sub-custodian has confirmed to the Custodian that the required
Deposit Securities (or the cash value thereof) have been delivered to the account of the relevant sub-custodian(s), the
Distributor and the Adviser shall be notified of such delivery, and the Trust will issue and cause the delivery of the Creation
Units.
In instances where the Trust accepts Deposit Securities for the purchase of a Creation
Unit, the Creation Unit may be purchased in advance of receipt by the Trust of all or a portion of the applicable
Deposit Securities, as described below. In these circumstances, the initial deposit will have a value greater than the NAV of
the shares on the date the order is placed in proper form, since in addition to available Deposit Securities, cash must be deposited
in an amount equal to the sum of (1) the Cash Component, plus (2) an additional amount of cash equal to a percentage of the
value, as set forth in the Participant Agreement, of the undelivered Deposit Securities (the “Additional Cash Deposit”), which shall be maintained in a general non-interest bearing collateral account. An additional amount of cash shall be required
to be deposited with the Trust, pending delivery of the missing Deposit Securities to the extent necessary to maintain the
Additional Cash Deposit with the Trust in an amount at least equal to the applicable percentage, as set forth in the Participant
Agreement, of the daily marked to value of the missing Deposit Securities. The Trust may use such Additional Cash Deposit to
buy the missing Deposit Securities at any time. Authorized Participants will be liable to the Trust for all costs, expenses,
dividends, income and taxes associated with missing Deposit Securities, including the costs incurred by the Trust in connection
with any such purchases. These costs will be deemed to include the amount by which the actual purchase price of the Deposit
Securities exceeds the value of such Deposit Securities on the day the purchase order was deemed received by the Distributor
plus the brokerage and related transaction costs associated with such purchases. The Trust will return any unused
portion of the Additional Cash Deposit once all of the missing Deposit Securities have been properly received by the Custodian,
or purchased by the Trust, and deposited into the Trust. In addition, a transaction fee, as set forth below under “Creation Transaction Fees” will be charged in all cases and an additional variable charge may also be applied. The delivery of Creation Units
so created generally will occur no later than the Settlement Date.
Acceptance of Orders of Creation Units. The Trust reserves the right to reject an order for Creation Units transmitted in
respect of a Fund at its discretion, including, without limitation, if (1) the order
is not in proper form; (2) the Deposit Securities or Deposit Cash, as applicable, delivered by the Participant are not as
disseminated through the facilities of the NSCC for that date by the Custodian; (3) the investor(s), upon obtaining the shares
ordered, would own 80% or more of the currently outstanding shares of a Fund; (4) the acceptance of the Fund Deposit would,
in the opinion of counsel, be unlawful; (5) the acceptance or receipt of the order for a Creation Unit would, in the opinion
of counsel to the Trust, be unlawful; or (6) in the event that circumstances outside the control of the Trust, the Custodian, the
Transfer Agent and/or the Adviser make it for all practical purposes not feasible to process orders for Creation Units. Examples
of such circumstances include: (1) acts of God or public service or utility problems such as fires, floods, extreme weather
conditions and power outages resulting in telephone, telecopy and computer failures; (2) market conditions or activities causing
trading halts; (3) systems failures involving computer or other information systems affecting the Trust, the Distributor,
the Custodian, the Transfer Agent, DTC, NSCC, Federal Reserve System or any other participant in the creation process; and
(4) other extraordinary events. The Trust or its agents shall communicate to the Authorized Participant its rejection of an
order. The Trust, the Transfer Agent, the Custodian and the Distributor are under no duty, however, to give notification of
any defects or irregularities in the delivery of Fund Deposits nor shall either of them incur any liability for the failure to give
any such notification. The Trust, the Transfer Agent, the Custodian and the Distributor shall not be liable for the rejection of
any purchase order for Creation Units. All questions as to the number of shares of each security in the Deposit Securities and
the validity, form, eligibility and acceptance for deposit of any securities to be delivered shall be determined by the Trust and the Trust’s determination shall be final and binding.
Redemption. Shares may be redeemed only in Creation Units at their NAV next determined after
receipt of a redemption request in proper form by a Fund through the Transfer Agent and only on a Business
Day. EXCEPT UPON LIQUIDATION OF A FUND, THE TRUST WILL NOT REDEEM SHARES IN AMOUNTS LESS THAN CREATION UNITS. Investors
must accumulate enough shares in the secondary market to constitute a Creation Unit
in order to have such shares redeemed by the Trust. There can be no assurance, however, that there will be sufficient liquidity
in the public trading market at any time to permit assembly of a Creation Unit. Investors should expect to incur brokerage
and other costs in connection with assembling a sufficient number of shares to constitute a redeemable Creation Unit.
Statement of Additional Information | Davis ETFs | 35
With respect to each Fund, the Custodian, through the NSCC, makes available immediately
prior to the opening of business on the NYSE (currently 9:30 a.m. Eastern time) on each Business Day, the list of the names and share quantities of each Fund’s portfolio securities that will be applicable (subject to possible amendment or correction)
to redemption requests received in proper form (as defined below) on that day (“Fund Securities”). Fund Securities received on redemption may not be identical to Deposit Securities.
Redemption proceeds for a Creation Unit are paid either in-kind or in cash, or a combination
thereof, as determined by the Trust. With respect to in-kind redemptions of a Fund, redemption proceeds for a Creation
Unit will consist of Fund Securities – as announced by the Custodian on the Business Day of the request for redemption received in proper form plus cash in an amount equal to the difference between the NAV of the shares being redeemed, as next
determined after a receipt of a request in proper form, and the value of the Fund Securities (the “Cash Redemption Amount”), less a fixed redemption transaction fee and any applicable additional variable charge, as set forth in the prospectus or this
SAI or as provided to Authorized Participant from time to time. In the event that the Fund Securities have a value
greater than the NAV of the shares, a compensating cash payment equal to the differential is required to be made by or through
an Authorized Participant by the redeeming shareholder. Notwithstanding the foregoing, at the Trust’s discretion, an Authorized Participant may receive the corresponding cash value of the securities in lieu of the in-kind securities value
representing one or more Fund Securities.
Procedures for Redemption of Creation Units. After the Trust has deemed an order for redemption received, the Trust will initiate procedures to transfer the requisite Fund Securities and the Cash Redemption
Amount to the Authorized Participant by the Settlement Date. With respect to in-kind redemptions of a Fund, the calculation
of the value of the Fund Securities and the Cash Redemption Amount to be delivered upon redemption will be made by the Custodian
according to the procedures set forth in the prospectus under “How Your Shares are Value,” computed on the Business Day on which a redemption order is deemed received by the Trust. Therefore, if a redemption order in proper form is submitted
to the Distributor by a DTC Participant by the specified time on the Order Placement Date, and the requisite number
of shares of a Fund are delivered to the Custodian prior to 2:00 p.m. or 3:00 p.m. Eastern time (per applicable instructions)
on the Settlement Date, then the value of the Fund Securities and the Cash Redemption Amount to be delivered will be determined
by the Custodian on such Order Placement Date. If the requisite number of shares of the Fund are not delivered by
2:00 p.m. or 3:00 p.m. Eastern time (per applicable instructions) on the Settlement Date, the Fund will not release the underlying
securities for delivery unless collateral is posted in such percentage amount of missing shares as set forth in the
Participant Agreement (marked-to-market daily).
With respect to in-kind redemptions of a Fund, in connection with taking delivery
of shares of Fund Securities upon redemption of Creation Units, an Authorized Participant must maintain appropriate
custody arrangements with a qualified broker-dealer, bank or other custody providers in each jurisdiction in which any of
the Fund Securities are customarily traded (or such other arrangements as allowed by the Trust or its agents), to which account
such Fund Securities will be delivered. Deliveries of redemption proceeds generally will be made within three Business Days
of the trade date.
If it is not possible to make other such arrangements, or if it is not possible to
effect deliveries of the Fund Securities, the Trust may in its discretion exercise its option to redeem such shares in cash, and the redeeming
investor will be required to receive its redemption proceeds in cash. In addition, an investor may request a redemption
in cash that a Fund may, in its sole discretion, permit. In either case, the investor will receive a cash payment equal
to the NAV of its shares based on the NAV of shares of the Fund next determined after the redemption request is received in proper
form (minus a redemption transaction fee and additional charge for requested cash redemptions specified above, to offset the Trust’s brokerage and other transaction costs associated with the disposition of Fund Securities). A Fund may also, in its
sole discretion, upon request of a shareholder, provide such redeemer a portfolio of securities that differs from the exact composition
of the Fund Securities, but does not differ in NAV.
An Authorized Participant submitting a redemption request is deemed to repeat representations
set forth in the Authorized Participant Agreement upon each redemption request. The Trust reserves the right to
verify these representations at its discretion, but will typically require verification with respect to a redemption request
from a Fund in connection with higher levels of redemption activity and/or short interest in a Fund. If the Authorized Participant,
upon receipt of a verification request, does not provide sufficient verification of its representations as determined
by the Trust, the redemption request will not be considered to have been received in proper form and may be rejected by the
Trust.
Redemptions of shares for Fund Securities will be subject to compliance with applicable
federal and state securities laws and each Fund (whether or not it otherwise permits cash redemptions) reserves the right
to redeem Creation Units for cash to the extent that the Trust could not lawfully deliver specific Fund Securities upon redemptions
or could not do so without first registering the Fund Securities under such laws. An Authorized Participant, or an
investor for which it is acting subject to a legal restriction with respect to a particular security, included in the Fund Securities
applicable to the redemption of Creation
Units may be paid an equivalent amount of cash. The Authorized Participant may request
the redeeming investor of the shares to complete an order form or to enter into agreements with respect to such matters
as compensating cash payment. Further, an Authorized Participant that is not a “qualified institutional buyer,” (“QIB”) as such term is defined under Rule 144A of the Securities Act, will not be able to receive Fund Securities that are restricted securities
eligible for resale under Rule 144A. An Authorized Participant may be required by the Trust to provide a written confirmation
with respect to QIB status in order to receive Fund Securities.
Statement of Additional Information | Davis ETFs | 36
The right of redemption may be suspended or the date of payment postponed with respect
to a Fund (1) for any period during which the Exchange is closed (other than customary weekend and holiday closings);
(2) for any period during which trading on the Exchange is suspended or restricted; (3) for any period during which an emergency
exists as a result of which disposal of the shares of a Fund or determination of the NAV of the shares is not reasonably
practicable; or (4) in such other circumstance as is permitted by the SEC.
Required Early Acceptance of Orders. Notwithstanding the foregoing, as described in the Participant Agreement and/or applicable order form, certain series of the Trust may require orders to be placed
up to one or more Business Days prior to the trade date, as described in the Participant Agreement or the applicable order form, in order to receive the trade date’s NAV. Orders to purchase shares of such funds that are submitted on the Business Day immediately
preceding a holiday or a day (other than a weekend) that the equity markets in the relevant foreign market are
closed may not be accepted. Authorized Participants may be notified that the cut-off time for an order may be earlier on
a particular Business Day, as described in the Participant Agreement and the applicable order form.
Creation and Redemption Transaction Fees. A transaction fee, as set forth in the table below, is imposed for the transfer and
other transaction costs associated with the purchase or redemption of Creation Units,
as applicable. Authorized Participants will be required to pay a fixed creation transaction fee and/or a fixed redemption
transaction fee, as applicable, on a given day regardless of the number of Creation Units created or redeemed on that day. A Fund
may adjust the transaction fee from time to time. An additional fee or a variable charge will be applied to certain creation
and redemption transactions, including nonstandard orders and whole or partial cash purchases or redemptions. With respect
to creation orders, Authorized Participants are responsible for the costs of transferring the securities constituting
the Deposit Securities to the account of the Trust and with respect to redemption orders, Authorized Participants are responsible
for the costs of transferring the Fund Securities from the Trust to their account or on their order. Investors who use the
services of a broker or other such intermediary may also be charged a fee for such services.
|
|
Transaction Fee
|
|
Davis Select U.S. Equity ETF
|
$150
|
|
Davis Select Financial ETF
|
$300
|
|
Davis Select International ETF
|
$300
|
|
Davis Select Worldwide ETF
|
$300
|
From time to time, a Fund may waive all or a portion of its applicable transaction
fee(s). An additional charge of up to three times the standard transaction fee may be charged to the extent a transaction is outside
of the clearing process.
In addition to the transaction fees listed above, a Fund may charge an additional
variable fee for creations and redemptions in cash to offset brokerage and impact expenses associated with the cash transaction.
The variable transaction fee will be calculated based on historical transaction cost data and the Adviser’s view of current market conditions; however, the actual variable fee charged for a given transaction may be lower or higher than the trading
expenses incurred by a Fund with respect to that transaction.
Statement of Additional Information | Davis ETFs | 37
Section IV:
General Information
General Information
This SAI should be read in conjunction with the Funds' prospectus. This SAI supplements
the information available in the Funds' prospectus.
Determining the Price of Shares
Valuation of Portfolio Securities. The valuation of the Funds' portfolio securities is described in the Funds' prospectus
and annual report.
Dividends and Distributions
The Funds’ prospectus describes the Funds’ dividend and distribution policies. This SAI supplements that discussion.
Each Fund intends to pay out dividends, if any, on an annual basis. Each Fund intends
to distribute its net realized capital gains, if any, to investors annually. A Fund may occasionally be required to make
supplemental distributions. Distributions in cash may be reinvested automatically in additional whole shares, only if the broker
through whom you purchased shares makes such option available. Your broker is responsible for distributing the income and
capital gain distributions to you. The Trust reserves the right to declare special distributions if, in its reasonable discretion,
such action is necessary or advisable to preserve the status of a Fund as a RIC or to avoid imposition of income or excise
taxes on undistributed income.
Capital Stock. Each Fund issues shares of beneficial interest, with no par value. The Board has
the right to establish additional series in the future, to determine the preferences, voting powers, rights and privileges
thereof and to modify such preferences, voting powers, rights and privileges without shareholder approval.
The Trust is not required to and does not intend to hold annual meetings of shareholders. The Trust’s Declaration of Trust (the “Declaration”), requires a shareholder vote only on those matters where the 1940 Act requires a vote of shareholders and otherwise permits the Trustees to take actions without seeking the consent of shareholders.
For example, the Declaration gives the Trustees the authority to approve reorganizations between a Fund and another entity,
such as another exchange-traded fund, or the sale of all or substantially all of a Fund’s assets, or the termination of the Trust or a Fund without shareholder approval if the 1940 Act would not require such approval. Each share has one vote with respect
to matters upon which a shareholder vote is required, consistent with the requirements of the 1940 Act and the rules promulgated
thereunder.
Shares of all series of the Trust vote together as a single class except as otherwise
required by the 1940 Act, or if the matter being voted on affects only a particular series; and, if a matter affects a particular
series differently from other series, the shares of that series will vote separately on such matter.
The Trustees establish the number of Trustees and may fill vacancies on the Board,
except when election of Trustees by the shareholders is required under the 1940 Act. Trustees are then elected by a plurality
of votes cast by shareholders at a meeting at which a quorum is present. The Declaration also provides that Trustees may be removed,
with cause, by a vote of shareholders holding at least two-thirds of the voting power of the Trust, or by a
vote of two-thirds of the remaining Trustees. “Cause” requires willful misconduct, dishonesty, fraud or a felony conviction. The provisions of the Declaration relating to the election and removal of Trustees may not be amended without the approval of two-thirds
of the Trustees.
Under the Declaration, by becoming a shareholder of a Fund, each shareholder is expressly
held to have agreed to be bound by the provisions of the Declaration and the Trust’s By-Laws. The Declaration may, except in limited circumstances, be amended by the Trustees in any respect without a shareholder vote. Shareholders may be required
to disclose information on direct or indirect ownership of Fund shares in order to comply with various laws applicable
to a Fund or as the Trustees may determine, and ownership of Fund shares may be disclosed by a Fund if so required by law or regulation.
In addition, pursuant to the Declaration, the Trustees may, in their discretion, require the Trust to redeem shares
held by any shareholder for any reason under terms set by the Trustees.
In order to permit legitimate inquiries and claims while avoiding the time, expense,
distraction and other harm that can be caused to a Fund or its shareholders as a result of spurious shareholder claims, demands
and derivative actions, the Declaration provides a detailed process for the bringing of derivative actions by shareholders,
and provides that actions that are derivative in nature may not be brought directly. Consistent with applicable Delaware law, prior
to bringing a derivative action, a demand must first be made on the Trustees. The Declaration details various information, certifications,
undertakings and acknowledgements that must be included in the demand. If a majority of the Trustees
who are considered independent for the purposes of considering the demand determine that maintaining the suit would not be
in the best interests of a Fund, the Trustees are required to reject the demand and the complaining shareholder may not
proceed with the derivative action unless the shareholder is able to sustain the burden of proof to a court that the decision
of the Trustees not to pursue the requested action was not a good faith exercise of their business judgment on behalf of a Fund.
In making such a determination, a Trustee is not considered to have a personal financial interest by virtue of being compensated
for their services as a Trustee. If a demand is rejected, the complaining shareholder may be responsible for the Fund’s costs and expenses if a court determines that a derivative action was made without reasonable cause or for an improper purpose,
if a derivative or direct action is dismissed on the basis of a failure to comply with the procedural provisions relating
to shareholder actions as set forth in the Declaration or if a direct action is dismissed by a court for failure to state a claim.
Any shareholder bringing an action against
Statement of Additional Information | Davis ETFs | 38
a Fund waives the right to trial by jury to the fullest extent permitted by law and
any action commenced by a shareholder may be brought only in the U.S. District Court for the District of Delaware or if any
such action may not be brought in that court, then in the Delaware Court of Chancery (the “Chosen Courts”), under the terms of the Declaration. Except as prohibited by law, if a shareholder commences an applicable action in a court other than a Chosen
Court, the shareholder may be obligated to reimburse the Fund and any applicable Trustee or officer of the Fund made party
to such proceeding for the costs and expenses (including attorneys’ fees) incurred in connection with any successful motion to dismiss, stay or transfer of the action.
The Declaration specifically provides, however, that no provision of the Declaration
is effective to require a waiver of compliance with any provision of, or restrict any shareholder rights expressly granted
by, the Securities Act of 1933, as amended, the Securities Exchange act of 1934, as amended, or the 1940 Act, or any
rule, regulation or order of the SEC thereunder. The provisions of the Declaration are severable, and if the Trustees determine,
with the advice of counsel, that any such provision, in whole or in part, conflict with applicable laws and regulations,
the conflicting provisions, or part or parts thereof, will be deemed to be not part of the Declaration (provided, that any such
determination will not render any of the remaining provisions invalid or improper).
The Declaration contains an express disclaimer of shareholder liability for acts or
obligations of the Trust and requires that notice of this disclaimer be given in each agreement, obligation or instrument entered
into or executed by the Trust or the Trustees. The Declaration further provides for indemnification out of the assets and
property of the Trust for all losses and expenses of any shareholder held personally liable for the obligations of the Trust.
Thus, the risk of a shareholder incurring financial loss on account of shareholder liability is limited to circumstances in
which both inadequate insurance existed and the Trust or the Fund itself was unable to meet its obligations. The Trust believes
the likelihood of the occurrence of these circumstances is remote.
The Declaration further provides that a Trustee acting in their capacity as Trustee
is not personally liable to any person other than the Trust or its series, in connection with the affairs of the Trust or for any
act, omission or obligation of the Trust. A Trustee is liable only for their own bad faith, willful misfeasance, gross negligence
or reckless disregard of their duties involved in the conduct of their office. The Declaration requires the Trust to indemnify
any persons who are or who have been Trustees, officers or employees of the Trust for any liability for actions or failure
to act except to the extent prohibited by applicable federal law. In making any determination as to whether any person is entitled
to the advancement of expenses in connection with a claim for which indemnification is sought, such person is entitled
to a rebuttable presumption that they did not engage in conduct for which indemnification is not available. The Declaration
provides that any Trustee who serves as Chair of the Board of Trustees or of a committee of the Board of Trustees, Lead Independent
Trustee, or Audit Committee Financial Expert, or in any other similar capacity will not be subject to any greater
standard of care or liability because of such position.
Shareholder inquiries may be made by writing to the Trust, c/o the Adviser, Davis
Selected Advisers, L.P., at 2949 East Elvira Road, Suite 101, Tucson, Arizona 85756.
Federal Income Taxes
The Funds’ prospectus provides a general discussion of federal income taxes. This SAI supplements that discussion.
This discussion is not intended to be a full discussion of all the aspects of the
federal income tax law and its effects on the Funds and their shareholders. Shareholders may be subject to state and local taxes
on distributions. Each investor should consult their own tax adviser regarding the effect of federal, state and local taxes
on any investment in a Fund.
If a Fund qualifies for treatment as a RIC, the Fund will not be subject to federal
income tax on income and gains that are distributed in a timely manner to its shareholders in the form of dividends.
In order to qualify as a RIC under the Code, each Fund must distribute annually to
its shareholders at least 90% of its net investment income (which, includes dividends, taxable interest and the excess of net
short-term capital gains over net long-term capital losses, less operating expenses) and at least 90% of its net tax exempt interest
income, for each tax year, if any (the “Distribution Requirement”) and also must meet certain additional requirements. Among these requirements are the following: (1) at least 90% of each Fund’s gross income each taxable year must be derived from dividends, interest, payments with respect to certain securities loans, and gains from the sale or other disposition
of stock, securities, or foreign currencies, or other income (including but not limited to gains from options, futures or forward
contracts) derived with respect to its business of investing in such stock, securities, or currencies, and net income derived
from an interest in a qualified publicly traded partnership (the “Qualifying Income Test”); and (2) at the close of each quarter of each Fund’s taxable year: (a) at least 50% of the value of each Fund’s total assets must be represented by cash and cash items, U.S. Government securities, securities of other RICs and other securities, with such other securities limited, in respect
to any one issuer, to an amount not greater than 5% of the value of each Fund’s total assets and that does not represent more than 10% of the outstanding voting securities of such issuer, including the equity securities of a qualified publicly traded partnership,
and (b) not more than 25% of the value of each Fund’s total assets is invested in the securities (other than U.S. Government securities or the securities of other RICs) of any one issuer or the securities (other than the securities of another RIC) of
two or more issuers that a Fund controls and which are engaged in the same or similar trades or businesses or related trades or
businesses, or the securities of one or more qualified publicly traded partnerships (the “Asset Test”).
Statement of Additional Information | Davis ETFs | 39
If, for any taxable year, a Fund was to fail to qualify as a RIC or was to fail to
meet the distribution requirement described above, it would be taxed in the same manner as an ordinary corporation and distributions
to its shareholders would not be deductible by the Fund in computing its taxable income. In addition, a Fund’s distributions, to the extent derived from the Fund’s current and accumulated earnings and profits, including any distributions of net long-term capital gains, would be taxable to shareholders as ordinary dividend income for federal income tax purposes.
However, such dividends would be eligible, subject to any generally applicable limitations, (1) to be treated as qualified
dividend income in the case of shareholders taxed as individuals; and (2) for the dividends-received deduction in
the case of corporate shareholders. Moreover, the Fund would be required to pay out its earnings and profits accumulated
in that year in order to qualify for treatment as a RIC in a subsequent year. Under certain circumstances, a Fund may be
able to cure a failure to qualify as a RIC, but in order to do so the Fund may incur significant Fund-level taxes and may be forced
to dispose of certain assets. If a Fund failed to qualify as a RIC for a period greater than two taxable years, the Fund would
generally be required to recognize any net built-in gains with respect to certain of its assets upon a disposition of such
assets within ten years of qualifying as a RIC in a subsequent year.
Each Fund intends to distribute at least annually to its shareholders substantially
all of its investment company taxable income (computed without regard to the dividends-paid deduction) and net capital gain (the excess of the Fund’s net long-term capital gain over its net short-term capital loss). Investment income that is retained by
a Fund will generally be subject to tax at regular corporate rates. If a Fund retains any net capital gain, that gain will be
subject to tax at corporate rates, but the Fund may designate the retained amount as undistributed capital gains in a notice to its
shareholders who (1) will be required to include in income for federal income tax purposes, as long-term capital gain, their
shares of such undistributed amount; (2) will be deemed to have paid their proportionate shares of the tax paid by the Fund
on such undistributed amount against their federal income tax liabilities, if any; and (3) will be entitled to claim refunds
on a properly filed U.S. tax return to the extent the credit exceeds such liabilities. For federal income tax purposes, the tax basis
of shares owned by a shareholder of a Fund will be increased by an amount equal to the difference between the amount of undistributed
capital gains included in the shareholder’s gross income and the tax deemed paid by the shareholder.
If a Fund fails to distribute in a calendar year an amount at least equal to the sum
of 98% of its ordinary income for such year and 98.2% of its capital gain net income for the one-year period ending October 31
of such year, plus any retained amount from the prior year, the Fund will be subject to a non-deductible 4% excise tax on
the undistributed amount. For these purposes, the Fund will be treated as having distributed any amount on which it has
been subject to corporate income tax for the taxable year ending within the calendar year. Each Fund intends to declare and
pay dividends and distributions in the amounts and at the times necessary to avoid the application of the 4% excise tax,
although there can be no assurance that it will be able to do so.
A Fund may elect to treat part or all of any “qualified late year loss” as if it had been incurred in the succeeding taxable year in determining the Fund’s taxable income, net capital gain, net short-term capital gain, and earnings and profits. A “qualified late year loss” generally includes net capital loss, net long-term capital loss or net short-term capital loss incurred after October 31 of the current taxable year, and certain other late-year losses.
If a Fund has a “net capital loss” (that is, capital losses in excess of capital gains), the excess of the Fund’s net short-term capital losses over its net long-term capital gains is treated as a short-term capital loss arising on the first day of the Fund’s next taxable year, and the excess (if any) of the Fund’s net long-term capital losses over its net short-term capital gains is treated as a long-term capital loss arising on the first day of the Fund’s next taxable year.
Distributions. Distributions are generally taxable whether shareholders receive them in cash or
reinvest them in additional shares. Moreover, distributions on a Fund’s shares are generally subject to federal income tax as described herein to the extent they do not exceed the Fund’s realized income and gains, even though such distributions may economically represent a return of a particular shareholder’s investment. Investors may therefore wish to avoid purchasing shares at a time when a Fund’s NAV reflects gains that are either unrealized, or realized but not distributed. Realized
income and gains must generally be distributed even when a Fund’s NAV also reflects unrealized losses.
Dividends and other distributions by a Fund are generally treated under the Code as
received by the shareholders at the time the dividend or distribution is made. However, if any dividend or distribution is
declared by a Fund in October, November or December of any calendar year and payable to its shareholders of record on a specified
date in such a month but is actually paid during the following January, such dividend or distribution will be deemed to
have been received by each shareholder on December 31 of the year in which the dividend was declared.
Distributions by a Fund of investment income are generally taxable as ordinary income.
Taxes on distributions of capital gains are determined by how long the Fund owned the assets that generated those gains, rather
than how long a shareholder has owned their Fund shares. Sales of assets held by a Fund for more than one year generally
result in long-term capital gains and losses, and sales of assets held by a Fund for one year or less generally result in
short-term capital gains and losses. Distributions from a Fund’s net capital gain that are properly reported by the Fund as capital gain dividends (“Capital Gain Dividends”) will be taxable as long-term capital gains. For individuals, long-term capital gains are subject to tax at reduced maximum tax rates. Distributions of gains from the sale of investments that a Fund
owned for one year or less will be taxable as ordinary income.
Statement of Additional Information | Davis ETFs | 40
For non-corporate shareholders, distributions of investment income reported by a Fund as derived from “qualified dividend income” will be taxed at the rates applicable to long-term capital gain, provided holding period and other requirements are met at both the shareholder and Fund level. In order for some portion of the dividends
received by a Fund shareholder to be “qualified dividend income,” the Fund making the distribution must meet holding period and other requirements with respect to some portion of the dividend-paying stocks in its portfolio and the shareholder
must meet holding period and other requirements with respect to the Fund’s shares. A dividend will not be treated as qualified dividend income (at either the Fund or shareholder level) (1) if the dividend is received with respect to any share of
stock held for fewer than 61 days during the 121-day period beginning on the date that is 60 days before the date on which such
share becomes ex-dividend with respect to such dividend (or, in the case of certain preferred stock, 91 days during the 181-day
period beginning 90 days before the ex-dividend date); (2) to the extent that the recipient is under an obligation (whether pursuant
to a short sale or otherwise) to make related payments with respect to positions in substantially similar or related property;
(3) if the recipient elects to have the dividend income treated as investment income for purposes of the limitation on deductibility
of investment interest; or (4) if the dividend is received from a foreign corporation that is (a) not eligible for the
benefits of a comprehensive income tax treaty with the United States (with the exception of dividends paid on stock of such a foreign
corporation that is readily tradable on an established securities market in the United States), or (b) treated as a passive
foreign investment company.
In general, distributions of investment income reported by a Fund as derived from
qualified dividend income will be treated as qualified dividend income by a shareholder taxed as an individual, provided the shareholder
meets the holding period and other requirements described above with respect to the Fund’s shares. To the extent that a Fund makes a distribution of income received by the Fund in lieu of dividends (a “substitute payment”) with respect to securities on loan pursuant to a securities lending transaction, such income will not constitute qualified dividend income to
individual shareholders and will not be eligible for the dividends received deduction for corporate shareholders.
Dividends and distributions from a Fund and capital gain on the sale of Fund shares
are generally taken into account in determining a shareholder’s “net investment income” for purposes of the Medicare contribution tax applicable to certain individuals, estates and trusts.
In the case of corporate shareholders, Fund distributions (other than capital gain
distributions) generally qualify for the dividends-received deduction to the extent such distributions are so reported and
do not exceed the gross amount of qualifying dividends received by such Fund for the year. Generally, and subject to certain limitations
(including certain holding period limitations), a dividend will be treated as a qualifying dividend if it has been received
from a domestic corporation. All such qualifying dividends (including the deducted portion) must be included in your alternative
minimum taxable income calculation.
If a Fund makes distributions in excess of the Fund’s current and accumulated earnings and profits in any taxable year, the excess distribution to each shareholder will be treated as a return of capital to the extent of the shareholder’s tax basis in its shares, and will reduce the shareholder’s tax basis in its shares. After the shareholder’s basis has been reduced to zero, any such distributions will result in a capital gain, assuming the shareholder holds their
shares as capital assets. A reduction in a shareholder’s tax basis in its shares will reduce any loss or increase any gain on a subsequent taxable disposition by the shareholder of its shares.
Sale or Exchange of Shares. A sale or exchange of shares in a Fund may give rise to a gain or loss. In general,
any gain or loss realized upon a taxable disposition of shares will be treated as long-term capital
gain or loss if the shares have been held for more than 12 months. Otherwise, the gain or loss on the taxable disposition of
shares will be treated as short-term capital gain or loss. However, any loss realized upon a taxable disposition of shares held
for six months or less will be treated as long-term, rather than short-term, to the extent of any long-term capital gain distributions
received (or deemed received) by the shareholder with respect to the shares. All or a portion of any loss realized upon
a taxable disposition of shares will be disallowed if substantially identical shares of the Fund are purchased within 30 days
before or after the disposition. In such a case, the basis of the newly purchased shares will be adjusted to reflect the disallowed
loss.
Backup Withholding. A Fund (or financial intermediaries, such as brokers, through which a shareholder
holds Fund shares) generally is required to withhold and to remit to the U.S. Treasury a percentage of
the taxable distributions and sale or redemption proceeds paid to any shareholder who fails to properly furnish a correct
taxpayer identification number, who has under-reported dividend or interest income, who has failed to certify that they are
a U.S. person (including a resident alien) or who fails to certify that they are not subject to such withholding. The backup withholding
tax rate is 28%. Backup withholding is not an additional tax. Any amounts withheld may be credited against the shareholder’s U.S. federal income tax liability, provided the appropriate information is furnished to the Internal Revenue Service (the “IRS”).
Federal Tax Treatment of Certain Fund Investments. Transactions of a Fund in options, futures contracts, hedging transactions, forward contracts, swap agreements, straddles and foreign currencies
may be subject to various special and complex tax rules, including mark-to-market, constructive sale, straddle, wash sale
and short sale rules. These rules could affect a Fund’s ability to qualify as a RIC, affect whether gains and losses recognized by a Fund are treated as ordinary income or capital gain, accelerate the recognition of income to a Fund, and/or defer a Fund’s ability to recognize losses. These rules may in turn affect the amount, timing or character of the income distributed to shareholders
by a Fund.
Each Fund is required, for federal income tax purposes, to mark-to-market and recognize
as income for each taxable year its net unrealized gains and losses as of the end of such year on certain regulated futures
contracts, foreign currency contracts and
Statement of Additional Information | Davis ETFs | 41
options that qualify as Section 1256 contracts in addition to the gains and losses
actually realized with respect to such contracts during the year. Gain or loss from Section 1256 contracts that are required
to be marked-to-market annually will generally be 60% long-term and 40% short-term capital gain or loss. Application of
this rule may alter the timing and character of distributions to shareholders.
With respect to investments in zero coupon securities that are sold at original issue
discount and thus do not make periodic cash interest payments, a Fund will be required to include as part of its current
income the imputed interest on such obligations even though the Fund has not received any interest payments on such obligations during
that period. Because a Fund intends to distribute substantially all of its net investment income to its shareholders,
the Fund may have to sell Fund securities to distribute such imputed income that may occur at a time when the Adviser would not
have chosen to sell such securities and that may result in taxable gain or loss.
Any market discount recognized on a bond is taxable as ordinary income. A market discount
bond is a bond acquired in the secondary market at a price below redemption value or adjusted issue price if issued
with original issue discount. Absent an election by a Fund to include the market discount in income as it accrues, gain on the Fund’s disposition of such an obligation will be treated as ordinary income rather than capital gain to the extent of the accrued
market discount.
A Fund may invest in inflation-linked debt securities. Any increase in the principal
amount of an inflation-linked debt security will be original interest discount, which is taxable as ordinary income and is required
to be distributed, even though the Fund will not receive the principal, including any increase thereto, until maturity. As
noted above, if a Fund invests in such securities it may be required to liquidate other investments, including at times when it is not
advantageous to do so, in order to satisfy its distribution requirements and to eliminate any possible taxation at the Fund level.
Foreign Investments. Income received by a Fund from sources within foreign countries (including, for example,
dividends or interest on stock or securities of non-U.S. issuers) may be subject to withholding
and other taxes imposed by such countries. Tax treaties between such countries and the U.S. may reduce or eliminate such taxes.
If more than 50% of the value of a Fund’s total assets at the close of their taxable year consists of stocks or securities of foreign corporations, the Fund will be eligible to and intends to file an election with the
IRS that may enable shareholders, in effect, to receive either the benefit of a foreign tax credit, or a deduction from such taxes,
with respect to any foreign and U.S. possessions income taxes paid by the Fund, subject to certain limitations. Pursuant
to the election, such Fund will treat those taxes as dividends paid to its shareholders. Each such shareholder will be required
to include a proportionate share of those taxes in gross income as income received from a foreign source and must treat the
amount so included as if the shareholder had paid the foreign tax directly. The shareholder may then either deduct the taxes
deemed paid by him or her in computing their taxable income or, alternatively, use the foregoing information in calculating
any foreign tax credit they may be entitled to use against the shareholders’ federal income tax. If a Fund makes the election, such Fund (or its administrative agent) will report annually to their shareholders the respective amounts per share of the Fund’s income from sources within, and taxes paid to, foreign countries and U.S. possessions.
Tax-Exempt Shareholders. Under current law, income of a RIC that would be treated as unrelated business taxable
income (“UBTI”) if earned directly by a tax-exempt entity generally will not be attributed as UBTI to a tax-exempt entity that is a shareholder in the RIC. Notwithstanding this “blocking” effect, a tax-exempt shareholder could realize UBTI by virtue of its investment in a Fund if (1) shares in the Fund constitute debt-financed property in
the hands of the tax-exempt shareholder within the meaning of Code Section 514(b); (2) if the Fund invests in REITs that hold
residual interests in REMICs; (3) the Fund invests in a REIT that is a taxable mortgage pool (“TMP”) or in a REIT that has a subsidiary that is a TMP; or (4) if the Fund holds residual interests in REMICs.
Non-U.S. Investors. In general, dividends, other than Capital Gain Dividends paid by a Fund to a shareholder
that is not a “U.S. person” within the meaning of the Code are subject to withholding of U.S. federal income tax at a rate of 30% (or lower applicable treaty rate) on distributions derived from taxable ordinary income. A Fund
may, under certain circumstances, report all or a portion of a dividend as an “interest-related dividend” or a “short-term capital gain dividend,” which would generally be exempt from this 30% U.S. withholding tax, provided certain other requirements
are met. Short-term capital gain dividends received by a nonresident alien individual who is present in the U.S. for a period
or periods aggregating 183 days or more during the taxable year are not exempt from this 30% withholding tax.
A beneficial holder of shares who is a non-U.S. person is not, in general, subject
to U.S. federal income tax on gains (and is not allowed a U.S. income tax deduction for losses) realized on a sale of shares of
a Fund or on Capital Gain Dividends, unless (1) such gain or dividend is effectively connected with the conduct of a trade or
business carried on by such holder within the United States; or (2) in the case of an individual holder, the holder is present in
the United States for a period or periods aggregating 183 days or more during the year of the sale or the receipt of the Capital
Gain Dividend and certain other conditions are met.
Ordinary dividends, redemption payments and certain Capital Gain Dividends paid after
June 30, 2014 to a non-U.S. shareholder that fails to meet certain requirements or make certain required certifications
are generally subject to withholding tax at a 30% rate. Under current IRS guidance, withholding on such payments will begin
at different times depending on the type of payment, the type of payee and when the shareholder’s account is or was opened. In general, withholding with respect to ordinary dividends began on July 1, 2014, although in many cases withholding on
ordinary dividends will begin on a later date. Withholding on redemption payments, proceeds of sales in respect of Fund shares
and certain Capital Gain Dividends is
Statement of Additional Information | Davis ETFs | 42
currently scheduled to begin on January 1, 2019. A non-U.S. shareholder may be exempt
from the withholding described in this paragraph under an intergovernmental agreement between the U.S. and a foreign
government, provided that the shareholder and the applicable foreign government comply with the terms of such agreement.
In order for a non-U.S. investor to qualify for an exemption from backup withholding, described above, the non-U.S.
investor must comply with special certification and filing requirements. Non-U.S. investors in a Fund should consult
their tax advisors in this regard.
A beneficial holder of shares who is a non-U.S. person may be subject to state and
local tax and to the U.S. federal estate tax, in addition to the federal income tax consequences referred to above. If a shareholder
is eligible for the benefits of a tax treaty, any income or gain effectively connected with a U.S. trade or business will generally
be subject to U.S. federal income tax on a net basis, only if it is also attributable to a permanent establishment maintained
by the shareholder in the United States.
Creation and Redemption of Creation Units. An Authorized Participant having the U.S. dollar as its functional currency for U.S. federal income tax purposes that exchanges securities for Creation Units generally
will recognize a gain or loss equal to the difference between (1) the sum of the value of the Creation Units at the time
of the exchange and any cash received by the Authorized Participant in the exchange; and (2) the sum of the exchanger’s aggregate basis in the securities surrendered and any cash paid for such Creation Units. All or a portion of any gain or loss recognized
by an Authorized Participant exchanging a currency other than its functional currency for Creation Units may be treated as
ordinary income or loss. A person who redeems Creation Units will generally recognize a gain or loss equal to the difference between the exchanger’s basis in the Creation Units and the sum of the aggregate U.S. dollar value of any securities received
plus the amount of any cash received for such Creation Units. The IRS, however, may assert that a loss that is realized
upon an exchange of securities for Creation Units by an Authorized Participant who does not mark-to-market its holdings may not
be currently deducted under the rules governing “wash sales,” or on the basis that there has been no significant change in economic position. All or some portion of any capital gain or loss realized upon the creation of Creation Units in exchange
for securities will generally be treated as long-term capital gain or loss if securities exchanged for such Creation Units have
been held for more than one year.
Any capital gain or loss realized upon the redemption of Creation Units will generally
be treated as long-term capital gain or loss if the Creation Units have been held for more than one year. Otherwise, such
capital gains or losses will be treated as short-term capital gains or losses.
Persons exchanging securities for Creation Units should consult their own tax advisors
with respect to the tax treatment of any creation or redemption transaction and whether the wash sales rule applies and when
a loss might be deductible.
Section 351. The Trust on behalf of each Fund has the right to reject an order for a purchase of
shares of a Fund if the purchaser (or any group of purchasers) would, upon obtaining the shares so ordered,
own 80% or more of the outstanding shares of the Fund and if, pursuant to Section 351 of the Code, the Fund would have
a basis in the securities different from the value of such securities on the date of deposit. The Trust also has the right to require
information necessary to determine beneficial share ownership for purposes of the 80% determination.
Certain Reporting Regulations. Under U.S. Treasury regulations, generally, if a shareholder recognizes a loss of
$2 million or more for an individual shareholder or $10 million or more for a corporate shareholder
(or certain greater amounts over a combination of years), the shareholder must file with the IRS a disclosure statement
on IRS Form 8886. Direct shareholders of portfolio securities are in many cases excepted from this reporting requirement,
but under current guidance, shareholders of a RIC are not excepted. Significant penalties may be imposed for the failure to comply
with the reporting regulations. The fact that a loss is reportable under these regulations does not affect the legal determination of whether the taxpayer’s treatment of the loss is proper. Shareholders should consult their tax advisors to determine the
applicability of these regulations in light of their individual circumstances.
Cost Basis Reporting. The cost basis of shares acquired by purchase will generally be based on the amount
paid for the shares and then may be subsequently adjusted for other applicable transactions as required
by the Code. The difference between the selling price and the cost basis of shares generally determines the amount of the
capital gain or loss realized on the sale or exchange of shares. Contact the broker through whom you purchased your shares to obtain
information with respect to the available cost basis reporting methods and elections for your account.
General Considerations
The federal income tax discussion set forth above is for general information only.
Prospective investors should consult their tax advisors regarding the specific federal income tax consequences of purchasing,
holding and disposing of shares of a Fund, as well as the effect of state, local and foreign tax law and any proposed tax law
changes.
Procedures and Shareholder Rights Are Described by Current Prospectus and Other Disclosure
Documents
Among other disclosures, the Funds' most current prospectus, SAI, annual and semi-annual
reports, and other documents describe: (1) the procedures which the Funds follow when interacting with shareholders; and (2) shareholders’ rights. The Funds' procedures and shareholders’ rights may change from time to time to reflect changing laws, rules, and operations. The Funds' prospectus and other disclosure documents will be amended from time to time
to reflect these changes.
Statement of Additional Information | Davis ETFs | 43
Appendix A:
Quality Ratings of Debt Securities
Quality Ratings of Debt Securities
Moody’s Credit Ratings
|
Aaa
|
Obligations rated Aaa are judged to be of the highest quality, with minimal risk.
|
|
Aa
|
Obligations rated Aa are judged to be of high quality and are subject to very low
credit risk.
|
|
A
|
Obligations rated A are considered upper medium-grade-obligations and are subject
to low credit risk.
|
|
Baa
|
Obligations rated Baa are subject to moderate credit risk. They are considered medium-grade
and as such may
possess speculative characteristics.
|
|
Ba
|
Obligations rated Ba are judged to have speculative elements and are subject to substantial
credit risk.
|
|
B
|
Obligations rated B are considered speculative and are subject to high credit risk.
|
|
Caa
|
Obligations rated Caa are judged to be of poor standing and are subject to very high
credit risk.
|
|
Ca
|
Obligations rated Ca are highly speculative and are likely in, or very near, default,
with some prospect of recovery
in principal and interest.
|
|
C
|
Obligations rated C are the lowest-rated class of bonds, and are typically in default,
with little prospect for
recovery of principal and interest.
|
S&P Global’s Credit Ratings
|
AAA
|
Extremely strong capacity to meet financial commitments. Highest rating.
|
|
AA
|
Very strong capacity to meet financial commitments.
|
|
A
|
Strong capacity to meet financial commitments, but somewhat susceptible to adverse
economic conditions and
changes in circumstances.
|
|
BBB
|
Adequate capacity to meet financial commitments, but more subject to adverse economic
conditions.
|
|
BBB-
|
Considered lowest investment-grade by market participants.
|
|
BB+
|
Considered highest speculative-grade by market participants.
|
|
BB
|
Less vulnerable in near-term but faces major ongoing uncertainties to adverse business,
financial and economic
conditions.
|
|
B
|
More vulnerable to adverse business, financial and economic conditions but currently
has the capacity to meet
financial commitments.
|
|
CCC
|
Currently vulnerable and dependent on favorable business, financial and economic conditions
to meet financial
commitments.
|
|
CC
|
Highly vulnerable; default has not yet occurred, but is expected to be a virtual certainty.
|
|
C
|
Currently highly vulnerable to non-payment, and ultimate recovery is expected to be
lower than that of higher rated
obligations.
|
|
D
|
Payment default on a financial commitment or breach or an imputed promise; also used
when a bankruptcy
petition has been filed or similar action taken.
|
Statement of Additional Information | Davis ETFs | 44
Appendix B:
Summary of the Adviser’s Proxy Voting Policies and Procedures
Summary of the Adviser’s Proxy Voting Policies and Procedures
Davis Selected Advisers, L.P. (the “Adviser”) votes on behalf of its clients in matters of corporate governance through the proxy voting process. The Adviser takes its ownership responsibilities very seriously
and believes the right to vote proxies for its clients’ holdings is a significant asset of the clients. The Adviser exercises its voting responsibilities as a fiduciary, solely with the goal of maximizing the value of its clients’ investments.
The Adviser votes proxies with a focus on the investment implications of each issue.
For each proxy vote, the Adviser takes into consideration its duty to clients and all other relevant facts known to the Adviser
at the time of the vote. Therefore, while these guidelines provide a framework for voting, votes are ultimately cast on a case-by-case
basis.
The Adviser has adopted written Proxy Voting Policies and Procedures and established
a Proxy Oversight Group to oversee voting policies and deal with potential conflicts of interest. In evaluating issues,
the Proxy Oversight Group may consider information from many sources, including the Portfolio Managers for each client account,
management of a company presenting a proposal, shareholder groups, and independent proxy research services.
While the Proxy Oversight Group may consider information from many sources, there
is no requirement that it consider each source and the Proxy Oversight Group shall have the discretion in its professional
judgement to determine each matter to be voted on. The Adviser may utilize research provided by an independent third-party
proxy advisory firm. As a policy, the Adviser does not follow the voting recommendations provided by these firms.
Clients may obtain a copy of the Adviser’s Proxy Voting Policies and Procedures, and/or a copy of how their own proxies were voted, by writing to:
Davis Selected Advisers, L.P.
Attn: Chief Compliance Officer
2949 East Elvira Road, Suite 101
Tucson, Arizona, 85756
Attn: Chief Compliance Officer
2949 East Elvira Road, Suite 101
Tucson, Arizona, 85756
Guiding Principles
Creating Value for Existing Shareholders. The most important factors that the Adviser will consider in evaluating proxy issues are: (1) the company’s or management’s long-term track record of creating value for shareholders (e.g., in general, the Adviser will consider the recommendations of a management with a good record of creating
value for shareholders as more credible than the recommendations of a management with a poor record); (2) whether, in the Adviser’s estimation, the current proposal being considered will significantly enhance or detract from long-term value
for existing shareholders; and (3) whether a poor record of long term performance resulted from poor management or from factors outside of management’s control.
Other factors which the Adviser will consider may include:
◼
Shareholder oriented management. One of the factors that the Adviser considers in selecting stocks for investment
is the presence of shareholder-oriented management. In general, such managements will have
a large ownership stake in the company. They will also have a record of taking actions and supporting policies designed
to increase the value of the company’s shares and thereby enhance shareholder wealth. The Adviser’s research analysts are active in meeting with top management of portfolio companies and in discussing their views on policies or actions
which could enhance shareholder value. Whether management shows evidence of responding to reasonable shareholder suggestions,
and otherwise improving general corporate governance, is a factor which may be taken into consideration
in proxy voting.
◼
Allow responsible management teams to run the business. Because the Adviser tries, generally, to invest with “owner oriented” managements (see above), it will vote with the recommendation of management on most routine matters, unless circumstances such as long standing poor performance or a change from its initial
assessment indicates otherwise. Examples include the election of directors and ratification of auditors. The Adviser
supports policies, plans, and structures that give management teams the appropriate latitude to run the business in the way
that is most likely to maximize value for owners. Conversely, the Adviser opposes proposals that limit management’s ability to do this. The Adviser will generally vote with management on shareholder social and environmental proposals on
the basis that their impact on share value is difficult to judge and is therefore best done by management.
◼
Preserve and expand the power of shareholders in areas of corporate governance. Equity shareholders are owners of the business, and company boards and management teams are ultimately accountable to them.
The Adviser will support policies, plans, and structures that promote accountability of the board and management
to owners, and align the interests of the board and management with owners. Examples include: annual election of all
board members and incentive plans that are contingent on delivering value to shareholders. The Adviser will generally
oppose proposals that reduce accountability or misalign interests, including but not limited to classified boards,
poison pills, excessive option plans, and repricing of options.
Statement of Additional Information | Davis ETFs | 45
◼
Support compensation policies that reward management teams appropriately for performance. The Adviser believes that well thought out incentives are critical to driving long-term shareholder value creation.
Management incentives ought to be aligned with the goals of long-term owners. In the Adviser’s view, the basic problem of skyrocketing executive compensation is not high pay for high performance, but high pay for mediocrity or
worse. In situations where the Adviser feels that the compensation practices at companies the Funds own are not acceptable,
the Adviser will exercise its discretion to vote against compensation committee members and specific compensation
proposals.
The Adviser exercises its professional judgment in applying these principles to specific proxy votes. The Adviser’s Proxy Policies and Procedures provide additional explanation of the analysis which the Adviser
may conduct when applying these guiding principles to specific proxy votes.
Conflicts of Interest
A potential conflict of interest arises when the Adviser has business interests that
may not be consistent with the best interests of its client. The Adviser’s Proxy Oversight Group is charged with resolving material potential conflicts of interest which it becomes aware of. It is charged with resolving conflicts in a manner that is consistent
with the best interests of clients. There are many acceptable methods of resolving potential conflicts, and the Proxy Oversight
Group exercises its judgment and discretion to determine an appropriate means of resolving a potential conflict in
any given situation:
◼
Votes consistent with the “General Proxy Voting Policies,” are presumed to be consistent with the best interests of clients;
◼
The Adviser may disclose the conflict to the client and obtain the client’s consent prior to voting the proxy;
◼
The Adviser may obtain guidance from an independent third-party;
◼
The potential conflict may be immaterial; or
◼
Other reasonable means of resolving potential conflicts of interest which effectively
insulate the decision on how to vote client proxies from the conflict.
Statement of Additional Information | Davis ETFs | 46
PART C
OTHER INFORMATION
Item 28.
Exhibits:
|
(a)(1)
|
|
|
(a)(2)
|
|
|
(b)
|
|
|
(c)
|
Not applicable.
|
|
(d)
|
|
|
(d)(i)
|
|
|
(e)
|
|
|
(f)
|
Not applicable.
|
|
(g)
|
|
|
(g)(i)
|
|
|
(h)
|
|
|
(h)(i)
|
|
|
(i)*
|
Opinion and Consent of Greenberg Traurig, LLP.
|
|
(j)*
|
Consent of independent registered public accountants.
|
|
(k)
|
Not applicable.
|
|
(l)
|
|
|
(m)
|
Not applicable.
|
|
(n)
|
Not applicable.
|
|
(o)
|
Reserved.
|
|
(p)(1)
|
Code of Ethics of Registrant and Davis Selected Advisers, L.P. as amended January
1,
2026.*
|
|
(p)(2)
|
|
|
(q)
|
*
filed herein
Item 29.
Persons Controlled by or Under Common Control with the Fund.
None.
Item 30.
Indemnification.
Pursuant to Delaware Code Ann. Title 12 § 3817, a Delaware statutory trust may provide in its governing instrument for the indemnification of its officers and Trustees from and against any
and all claims and demands whatsoever.
Section 8.4 of Article 8 of the Registrant’s Declaration of Trust provides:
The Trust shall indemnify to the fullest extent permitted by law each of its Trustees,
former Trustees, Trustees emeritus, Advisory Board Members and officers and persons who serve at the Trust’s request as directors, officers or trustees of another organization in which the Trust has any
interest as a shareholder, creditor, or otherwise, and may indemnify any trustee, director or officer of a predecessor
organization (each an “Indemnified Person”), and may indemnify its employees and agents, against all liabilities and expenses (including amounts paid in satisfaction of judgments, in compromise, as fines
and penalties, and expenses including reasonable accountants’ and counsel fees) reasonably incurred in connection with the defense or disposition of any action, suit or other proceeding of any kind and nature
whatsoever, whether brought in the right of the Trust or otherwise, and whether of a civil, criminal or
administrative nature, before any court or administrative or legislative body, including any appeal therefrom,
in which he or she may be involved as a party, potential party, non-party witness or otherwise or with
which he or she may be threatened, while as an Indemnified Person or thereafter, by reason of being or having
been such an Indemnified Person, except that no Indemnified Person shall be indemnified against
any liability to the Trust or its Shareholders to which such Indemnified Person would otherwise be subject
by reason of bad faith, willful misfeasance, gross negligence or reckless disregard of his or her duties
involved in the conduct of such Indemnified Person’s office (such willful misfeasance, bad faith, gross negligence or reckless disregard being referred to herein as “Disabling Conduct”). Expenses, including accountants’ and counsel fees so incurred by any such Indemnified Person (but excluding amounts paid
in satisfaction of judgments, in compromise or as fines or penalties), shall be promptly paid from time
to time, and the expenses of the Trust’s employees or agents may be paid from time to time, by the Trust or a Series in advance of the final disposition of any such action, suit or proceeding upon receipt
of an undertaking by or on behalf of such Indemnified Person to repay amounts so paid to the Trust if it is
ultimately determined that indemnification of such expenses is not authorized under this Article 8 and either
(i) such Indemnified Person provides security for such undertaking, (ii) the Trust is insured against losses
arising by reason of such payment, or (iii) a majority of a quorum of disinterested, non-party Trustees,
or independent legal counsel in a written opinion, determines, based on a review of readily available facts,
that there is reason to believe that such Indemnified Person ultimately will be found entitled to indemnification.
Item 31.
Business and Other Connections of the Investment Adviser.
Davis Selected Advisers, L.P. (“DSA”) and affiliated companies comprise a financial services organization whose business consists primarily of providing investment management services as the
investment adviser and manager for investment companies registered under the Investment Company Act of
1940,
unregistered domestic and off-shore investment companies, and as an investment adviser
to institutional and individual accounts. DSA also serves as sub-adviser to other investment companies.
Affiliated companies include:
Davis Investments, LLC: the sole general partner of DSA. Controlled by its sole member,
Christopher C. Davis.
Venture Advisers, Inc.: a corporation whose primary purpose is to hold limited partner
units in DSA.
Davis Selected Advisers – NY, Inc.: a wholly-owned subsidiary of DSA, is a federally registered investment adviser which serves as sub-adviser for many of DSA’s advisory clients.
Davis Distributors LLC: a wholly-owned subsidiary of DSA, is a registered broker-dealer
which serves as primary underwriter of Davis New York Venture Fund, Inc., Davis Series, Inc., Davis
Variable Account Fund, Inc. (herein collectively referred to as the “Davis Funds”), Selected American Shares, Inc., and Clipper Funds Trust.
Other business of a substantial nature that directors or officers of DSA are or have
been engaged in the last two years:
Lisa Cohen (4/25/89), 2949 East Elvira Road, Suite 101, Tucson, AZ 85756. Vice President and Secretary
of each of Davis New York Venture Fund, Inc., Davis Series, Inc., Davis Variable Account
Fund, Inc., Selected American Shares, Inc., Clipper Funds Trust, and Davis Fundamental ETF Trust.
Vice President, Chief Legal Officer, and Secretary, Davis Investments, LLC. Also serves as a senior
officer for several companies affiliated with DSA which are described above.
Christopher Davis (7/13/65), 620 Fifth Avenue, 3rd Floor, New York, NY 10020. A director and officer of each of Davis New York Venture Fund, Inc., Davis Series, Inc., Davis Variable Account
Fund, Inc., and Selected American Shares, Inc. President and Trustee of Clipper Funds Trust. Director,
Chairman of Davis Investments, LLC. Also serves as a director and/or senior officer for several companies
affiliated with DSA, which are described above. Director, Graham Holdings. Director, The Coca-Cola
Company.
Kenneth Eich (8/14/53), 2949 East Elvira Road, Suite 101, Tucson, AZ 85756. Executive Vice President and Principal Executive Officer of each of Davis New York Venture Fund, Inc., Davis
Series, Inc., Davis Variable Account Fund, Inc. Selected American Shares, Inc., Clipper Funds Trust; Trustee/Chairman,
Executive Vice President, and Principal Executive Officer of Davis Fundamental ETF
Trust. Chief Operating Officer of Davis Investments, LLC. Also serves as a senior officer for several
companies affiliated with DSA which are described above.
Douglas Haines (3/4/71), 2949 East Elvira Road, Suite 101, Tucson, AZ 85756. Vice President, Treasurer, Chief Financial Officer, Principal Financial Officer, and Principal Accounting Officer
of each of Davis New York Venture Fund, Inc., Davis Series, Inc., Davis Variable Account Fund., Inc.,
Selected American Shares, Inc., Clipper Funds Trust, and Davis Fundamental ETF Trust. Vice President
of Davis Investments, LLC.
Michaela McLoughry (3/21/81), 2949 East Elvira Road, Suite 101, Tucson, AZ 85756. Vice President and Chief Compliance Officer of each of Davis New York Venture Fund, Inc., Davis Series,
inc., Davis Variable Account Fund, Inc., Selected American Shares, Inc., Clipper Funds Trust,
and Davis Fundamental ETF Trust. Vice President of Davis Investments, LLC. Also serves as Chief Compliance
Officer for DSA and as a senior officer for several companies affiliated with DSA which are described
above.
Jeffrey Pittman (03/03/72), 2949 East Elvira Road, Suite 101, Tucson, AZ 85756. Assistant Secretary of the Davis Fundamental ETF Trust (consisting of four portfolios); Assistant Secretary,
Davis Selected Advisers, L.P., and also serves as an executive officer of certain companies affiliated
with the Adviser.
Gary Tyc (5/27/56), 2949 East Elvira Road, Suite 101, Tucson, AZ 85756. Vice President, Chief Financial
Officer, Treasurer, and Secretary of Davis Investments, LLC. Also serves as a senior
officer for several companies affiliated with DSA which are described above.
Russell Wiese (5/18/66), 620 Fifth Avenue, 3rd Floor, New York, NY 10020. Chief Marketing Officer of Davis Investments, LLC. Also serves as a director and/or senior officer for several
companies affiliated with DSA which are described above.
Item 32(a)
Foreside Fund Services, LLC (the “Distributor”) serves as principal underwriter for the following investment companies registered under the Investment Company Act of 1940,
as amended:
1.AB Active ETFs, Inc.
2.ABS Long/Short Strategies Fund
3.ActivePassive Core Bond ETF, Series of Trust for Professional Managers
4.ActivePassive Intermediate Municipal Bond ETF, Series of Trust for Professional Managers
5.ActivePassive International Equity ETF, Series of Trust for Professional Managers
6.ActivePassive U.S. Equity ETF, Series of Trust for Professional Managers
7.AdvisorShares Trust
8.AFA Private Credit Fund
9.AGF Investments Trust
10.AIM ETF Products Trust
11.Alexis Practical Tactical ETF, Series of Listed Funds Trust
12.AlphaCentric Prime Meridian Income Fund
13.American Century ETF Trust
14.AMG ETF Trust
15.Amplify ETF Trust
16.Applied Finance Dividend Fund, Series of World Funds Trust
17.Applied Finance Explorer Fund, Series of World Funds Trust
18.Applied Finance Select Fund, Series of World Funds Trust
19.Ardian Access LLC
20.ARK ETF Trust
21.ARK Venture Fund
22.Bitwise Funds Trust
23.BondBloxx ETF Trust
24.Bramshill Multi-Strategy Income Fund, Series of Investment Managers Series Trust
25.Bridgeway Funds, Inc.
26.Brinker Capital Destinations Trust
27.Brookfield Real Assets Income Fund Inc.
28.Build Funds Trust
29.Calamos Convertible and High Income Fund
30.Calamos Convertible Opportunities and Income Fund
31.Calamos Dynamic Convertible and Income Fund
32.Calamos Global Dynamic Income Fund
33.Calamos Global Total Return Fund
34.Calamos Strategic Total Return Fund
35.Carlyle Tactical Private Credit Fund
36.Cascade Private Capital Fund
37.Catalyst/Perini Strategic Income Fund
38.CBRE Global Real Estate Income Fund
39.Center Coast Brookfield MLP & Energy Infrastructure Fund
40.Cliffwater Corporate Lending Fund
41.Cliffwater Enhanced Lending Fund
42.Coatue Innovative Strategies Fund
43.
Cohen & Steers ETF Trust
44.
Convergence Long/Short Equity ETF, Series of Trust for Professional Managers
45.
CornerCap Small-Cap Value Fund, Series of Managed Portfolio Series
46.
CrossingBridge Ultra-Short Duration ETF, Series of Trust for Professional Managers
47.
Curasset Capital Management Core Bond Fund, Series of World Funds Trust
48.
Curasset Capital Management Limited Term Income Fund, Series of World Funds Trust
49.
CYBER HORNET S&P 500® and Bitcoin 75/25 Strategy ETF, Series of CYBER HORNET Trust
50.
Davis Fundamental ETF Trust
51.
Defiance BMNR Option Income ETF, Series of ETF Series Solutions
52.Defiance Connective Technologies ETF, Series of ETF Series Solutions
53.Defiance Drone and Modern Warfare ETF, Series of ETF Series Solutions
54.Defiance Quantum ETF, Series of ETF Series Solutions
55.Denali Structured Return Strategy Fund
56.Dodge & Cox Funds
57.DoubleLine ETF Trust
58.DoubleLine Income Solutions Fund
59.DoubleLine Opportunistic Credit Fund
60.DoubleLine Yield Opportunities Fund
61.DriveWealth ETF Trust
62.EIP Investment Trust
63.Ellington Income Opportunities Fund
64.ETF Opportunities Trust
65.Exchange Listed Funds Trust
66.Exchange Place Advisors Trust
67.FIS Trust
68.FlexShares Trust
69.Fortuna Hedged Bitcoin Fund, Series of Listed Funds Trust
70.Forum Funds
71.Forum Funds II
72.Forum Real Estate Income Fund
73.GMO ETF Trust
74.GoldenTree Opportunistic Credit Fund
75.Gramercy Emerging Markets Debt Fund, Series of Investment Managers Series Trust
76.Grayscale Funds Trust
77.Guinness Atkinson Funds
78.Harbor ETF Trust
79.Harris Oakmark ETF Trust
80.Hawaiian Tax-Free Trust
81.Horizon Kinetics Blockchain Development ETF, Series of Listed Funds Trust
82.Horizon Kinetics Energy and Remediation ETF, Series of Listed Funds Trust
83.Horizon Kinetics Inflation Beneficiaries ETF, Series of Listed Funds Trust
84.Horizon Kinetics Japan Owner Operator ETF, Series of Listed Funds Trust
85.Horizon Kinetics Medical ETF, Series of Listed Funds Trust
86.Horizon Kinetics SPAC Active ETF, Series of Listed Funds Trust
87.Horizon Kinetics Texas ETF, Series of Listed Funds Trust
88.Innovator ETFs Trust
89.Ironwood Institutional Multi-Strategy Fund LLC
90.Ironwood Multi-Strategy Fund LLC
91.
Jensen Quality Growth ETF, Series of Trust for Professional Managers
92.
John Hancock Exchange-Traded Fund Trust
93.
Kurv ETF Trust
94.
Lazard Active ETF Trust
95.
LDR Real Estate Value-Opportunity Fund, Series of World Funds Trust
96.
Lone Peak Value Fund, Series of World Funds Trust
97.
Mairs & Power Balanced Fund, Series of Trust for Professional Managers
98.
Mairs & Power Growth Fund, Series of Trust for Professional Managers
99.
Mairs & Power Minnesota Municipal Bond ETF, Series of Trust for Professional Managers
100.
Mairs & Power Small Cap Fund, Series of Trust for Professional Managers
101.
Manor Investment Funds
102.MoA Funds Corporation
103.Moerus Worldwide Value Fund, Series of Northern Lights Fund Trust IV
104.Morgan Stanley ETF Trust
105.Morgan Stanley Pathway Large Cap Equity ETF, Series of Morgan Stanley Pathway Funds
106.Morgan Stanley Pathway Small-Mid Cap Equity ETF, Series of Morgan Stanley Pathway
Funds
107.Morningstar Funds Trust
108.NEOS ETF Trust
109.Niagara Income Opportunities Fund
110.NXG Cushing® Midstream Energy Fund
111.NXG NextGen Infrastructure Income Fund
112.OTG Latin American Fund, Series of World Funds Trust
113.Overlay Shares Core Bond ETF, Series of Listed Funds Trust
114.Overlay Shares Foreign Equity ETF, Series of Listed Funds Trust
115.Overlay Shares Hedged Large Cap Equity ETF, Series of Listed Funds Trust
116.Overlay Shares Large Cap Equity ETF, Series of Listed Funds Trust
117.Overlay Shares Municipal Bond ETF, Series of Listed Funds Trust
118.Overlay Shares Short Term Bond ETF, Series of Listed Funds Trust
119.Overlay Shares Small Cap Equity ETF, Series of Listed Funds Trust
120.Palmer Square Funds Trust
121.Palmer Square Opportunistic Income Fund
122.Partners Group Private Income Opportunities, LLC
123.Perkins Discovery Fund, Series of World Funds Trust
124.Philotimo Focused Growth and Income Fund, Series of World Funds Trust
125.Plan Investment Fund, Inc.
126.Point Bridge America First ETF, Series of ETF Series Solutions
127.Precidian ETFs Trust
128.Rareview 2x Bull Cryptocurrency & Precious Metals ETF, Series of Collaborative Investment
Series Trust
129.Rareview Dynamic Fixed Income ETF, Series of Collaborative Investment Series Trust
130.Rareview Systematic Equity ETF, Series of Collaborative Investment Series Trust
131.Rareview Tax Advantaged Income ETF, Series of Collaborative Investment Series Trust
132.Rareview Total Return Bond ETF, Series of Collaborative Investment Series Trust
133.Renaissance Capital Greenwich Funds
134.REX ETF Trust
135.Reynolds Funds, Inc.
136.RMB Investors Trust
137.Robinson Opportunistic Income Fund, Series of Investment Managers Series Trust
138.
Robinson Tax Advantaged Income Fund, Series of Investment Managers Series Trust
139.
Roundhill Ball Metaverse ETF, Series of Listed Funds Trust
140.
Roundhill Cannabis ETF, Series of Listed Funds Trust
141.
Roundhill ETF Trust
142.
Roundhill Magnificent Seven ETF, Series of Listed Funds Trust
143.
Roundhill Sports Betting & iGaming ETF, Series of Listed Funds Trust
144.
Roundhill Video Games ETF, Series of Listed Funds Trust
145.
Rule One Fund, Series of World Funds Trust
146.
Russell Investments Exchange Traded Funds
147.Securian AM Real Asset Income Fund, Series of Investment Managers Series Trust
148.Six Circles Trust
149.Sound Shore Fund, Inc.
150.SP Funds Trust
151.Sparrow Funds
152.Spear Alpha ETF, Series of Listed Funds Trust
153.STF Tactical Growth & Income ETF, Series of Listed Funds Trust
154.STF Tactical Growth ETF, Series of Listed Funds Trust
155.Strategic Trust
156.Strategy Shares
157.Swan Hedged Equity US Large Cap ETF, Series of Listed Funds Trust
158.Tekla World Healthcare Fund
159.Tema ETF Trust
160.The 2023 ETF Series Trust
161.The Community Development Fund
162.The Cook & Bynum Fund, Series of World Funds Trust
163.The Private Shares Fund
164.The SPAC and New Issue ETF, Series of Collaborative Investment Series Trust
165.Third Avenue Trust
166.Third Avenue Variable Series Trust
167.Tidal Trust I
168.Tidal Trust II
169.Tidal Trust III
170.Tidal Trust IV
171.TIFF Investment Program
172.Timothy Plan High Dividend Stock ETF, Series of The Timothy Plan
173.Timothy Plan International ETF, Series of The Timothy Plan
174.Timothy Plan Market Neutral ETF, Series of The Timothy Plan
175.Timothy Plan US Large/Mid Cap Core ETF, Series of The Timothy Plan
176.Timothy Plan US Small Cap Core ETF, Series of The Timothy Plan
177.Total Fund Solution
178.Touchstone ETF Trust
179.Trailmark Series Trust
180.T-Rex 2X Inverse Bitcoin Daily Target ETF, Series of World Funds Trust
181.T-Rex 2X Inverse Ether Daily Target ETF, Series of World Funds Trust
182.T-Rex 2X Long Bitcoin Daily Target ETF, Series of World Funds Trust
183.T-Rex 2X Long Ether Daily Target ETF
184.U.S. Global Investors Funds
185.Union Street Partners Value Fund, Series of World Funds Trust
186.
Vest Bitcoin Strategy Managed Volatility Fund, Series of World Funds Trust
187.
Vest S&P 500® Dividend Aristocrats Target Income Fund, Series of World Funds Trust
188.Vest US Large Cap 10% Buffer Strategies Fund, Series of World Funds Trust
189.Vest US Large Cap 20% Buffer Strategies Fund, Series of World Funds Trust
190.Virtus Stone Harbor Emerging Markets Income Fund
191.Volatility Shares Trust
192.WEBs ETF Trust
193.Wedbush Series Trust
194.Wellington Global Multi-Strategy Fund
195.Wilshire Mutual Funds, Inc.
196.Wilshire Variable Insurance Trust
197.WisdomTree Trust
198.XAI Octagon Floating Rate & Alternative Income Term Trust
Item 32(b)
The following are the Officers and Manager of the Distributor, the Registrant’s underwriter. The Distributor’s main business address is 190 Middle Street, Suite 301, Portland, Maine 04101.
|
Name
|
Address
|
Position with Underwriter
|
Position with Registrant
|
|
Teresa Cowan
|
190 Middle Street, Suite 301,
Portland, ME 04101
|
President/Manager
|
None
|
|
Chris Lanza
|
190 Middle Street, Suite 301,
Portland, ME 04101
|
Vice President
|
None
|
|
Kate Macchia
|
190 Middle Street, Suite 301,
Portland, ME 04101
|
Vice President
|
None
|
|
Alicia Strout
|
190 Middle Street, Suite 301,
Portland, ME 04101
|
Vice President and Chief
Compliance Officer
|
None
|
|
Gabriel E. Edelman
|
190 Middle Street, Suite 301,
Portland, ME 04101
|
Secretary
|
None
|
|
Susan L. LaFond
|
190 Middle Street, Suite 301,
Portland, ME 04101
|
Treasurer
|
None
|
|
Weston Sommers
|
190 Middle Street, Suite 301,
Portland, ME 04101
|
Financial and Operations
Principal and Chief
Financial Officer
|
None
|
Item 32(c)
Not applicable.
Item 33.
Location of Accounts and Records.
Accounts and records are maintained at the offices of Davis Selected Advisers, L.P.,
2949 East Elvira Road, Suite 101, Tucson, Arizona 85756, and at the offices of the Registrant’s custodian and transfer agent, SS&C GIDS, One Congress Street, Suite 1, Boston, MA, 02114-2016.
Item 34.
Management Services.
Not applicable.
Item 35.
Undertakings.
None.
SIGNATURES
Pursuant to the requirements of the Securities Act of 1933 and the Investment Company
Act of 1940, the Registrant has caused this Registration Statement to be signed on its behalf by the
undersigned, duly authorized, in the City of Tucson and State of Arizona on February 26, 2026.
The Registrant hereby certifies that this Post-Effective Amendment meets all the requirements
for effectiveness under paragraph (b) of Rule 485 of the Securities Act of 1933
DAVIS FUNDAMENTAL ETF TRUST
|
*By:
|
/s/ Lisa Cohen
|
|
Lisa Cohen
|
|
|
Attorney-in-Fact
|
|
Pursuant to the requirements of the Securities Act of 1933, this Registration Statement
has been signed below by the following persons in the capacities indicated.
|
Signature
|
Title
|
Date
|
|
/s/ Kenneth Eich*
|
Principal Executive Officer
|
February 26, 2026
|
|
Kenneth Eich
|
|
|
|
/s/ Douglas Haines*
|
Principal Financial Officer; and
|
February 26, 2026
|
|
Douglas Haines
|
Principal Accounting Officer
|
|
|
*By:
|
/s/ Lisa Cohen
|
|
Lisa Cohen
|
|
|
Attorney-in-Fact
|
|
*
Lisa Cohen signs this document on behalf of the Registrant and each of the foregoing
officers pursuant to the power of attorney filed as Exhibit 28(q).
|
*By:
|
/s/ Lisa Cohen
|
|
Lisa Cohen
|
|
|
Attorney-in-Fact
|
|
DAVIS FUNDAMENTAL ETF TRUST
Pursuant to the requirements of the Securities Act of 1933, this Registration Statement
has been signed by the following persons in the capacities indicated.
|
Signature
|
Title
|
|
/s/ Kenneth Eich*
|
Trustee
|
|
Kenneth Eich
|
|
|
/s/ Thomas Tays*
|
Trustee
|
|
Thomas Tays
|
|
|
/s/ Ralph Egizi*
|
Trustee
|
|
Ralph Egizi
|
|
|
/s/ Lawrence Harris*
|
Trustee
|
|
Lawrence Harris
|
|
*
Lisa Cohen signs this document on behalf of each of the foregoing officers pursuant
to the power of attorney filed as Exhibit 28(q).
ATTACHMENTS / EXHIBITS
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